The Festering Fraud behind Food Safety Reform

"The general public must recognize that only after the demystification of U.S. agriculture will family farmers, labor, and consumers see beyond corporate agribusiness' manipulations to the point where they will recognize that both their mutual interests and the future of agriculture can be best decided through a system that not only practices political democracy, but economic democracy as well.

-- Ingolf Voegler

Introduction

Readers of the New York Times were recently treated to a rarely glimpsed view of how the globally-sourced industrial food complex assembles the raw ingredients of the omnipresent hamburger. In his startling expose entitled "E. Coli Path Shows Flaws in Ground Beef Inspection," Michael Moss provides a window from which to witness well-hidden meat industry practices that most people, judging from some six hundred comments left on the New York Times website within 24 hours of the article's publication, find thoroughly repulsive.[1]

Moss's article tracing the processing history of the E. coli-contaminated hamburger consumed by Stephanie Smith, which left her body ravaged and permanently disabled, has much to commend it. While detailing how Cargill shaves costs by scraping together its "American Chef's Selection Angus Beef Patties" from trimmings and mash-like products sold to it by no less than four suppliers, Moss uncovers how the company failed to follow its own safety plans without facing any interference from the USDA until some one got very, very sick.

However, the article leaves out critical information from its analysis that would help us understand why so much is wrong with the meat inspection process today. Filling in these gaps is important if we want to take the correct measures to improve the safety of our meat supply. Furthermore, if we don't gain a fuller understanding of how and why the meat industry's inspection process became an essentially unregulated, privatized affair, we are likely to repeat the same mistake and allow Congress to pass food "safety" legislation that will serve to make the world a safer place for the cartels controlling the global produce trade but do nothing at all for the safety of our food supply.

The vested interests behind the creation of the 2009 Food Safety Enhancement Act and its Senate companion bill S. 510, the FDA Food Safety Modernization Act, are the same vested interests who were behind the earlier deregulation of the meat and poultry inspection process. They aim to minimize the regulatory obstacles faced by transnational corporations engaged in international trade, which is increasingly becoming the movement of goods from one subsidiary affiliate to another subsidiary affiliate. And they're using the issue of food safety to con us into consenting to their wishes.

The Fundamental Fraud Undermining Food Safety

After reading Moss's article, one might conclude that what's needed to increase the safety of the food supply is more testing. But that response misses the bigger picture. As illuminating as Moss's article is, it completely ignores the fact that the meat and poultry inspection process underwent a radical transformation in the 90s that took away government meat and poultry inspectors' authority to ensure product safety and handed it over to the slaughter and processing companies themselves. Critics of this surrender of regulatory authority say it's the equivalent of expecting the driver of a speeding car to pull over and write themselves a ticket. It's hardly news that corporations exist to maximize profits, not ensure society's welfare. But if you have any doubts that the honor system adopted by the USDA isn't working, just ask Stephanie Smith.

So, how did one of the most regulated industries become deregulated? For this, we can thank vested interests for engineering a regulatory coup: mandating that Hazard Analysis Critical Control Point Plans (HACCP), pronounced "hassip', be applied to the raw food in/raw food out stages of food production.

Since the early 70s, HACCP had been used successfully and voluntarily as a food safety approach by industrial food processors. HACCP was originally designed to ensure product safety by including in the production process a "kill" step that rendered harmless any pathogens present in the food product. But along the way, it was decided that the approach should be mandated to raw meat processing alone. The problem is: in raw food in/raw food out food processing, such as meat slaughter and processing, there are no effective, definitive control steps available, such as cooking, to kill pathogens.

As explained by microbiologist Dr. William H. Sperber in a paper tellingly entitled "HACCP Does Not Work from Farm to Table": "It is not an accident that HACCP evolved at the food processing step of the Farm to Table supply chain. It is at this step that effective controls, such as cooking, drying, acidification, or refining are available to eliminate significant hazards: "Safety is assured by process control, not by finished product testing."[2].

Why should we listen to Dr. Sperber? Well, for starters, he's neither a lawyer nor a lobbyist whose positions and actions are dictated by an allegiance to vested interests. And, most significantly, this scientist, who's currently Cargill's Ambassador of Food Safety, has dedicated his professional life to food safety issues and the appropriate use of HACCP by industry.

Sperber's career began when he was hired by Pillsbury's Howard Bauman, the microbiologist who originally conceived and developed HACCP as an antidote to the unreliable quality-control system previously used by the company. After an unfortunate incident that resulted in Pillsbury having to recall baby food, the company's president demanded that Bauman ensure no Pillsbury product would ever again tar the company's reputation.[3]

Prior to the development of HACCP, quality control consisted of testing batches of product for quality and safety. However, the problem with testing product samples is that the technique, if done properly, requires testing a great deal of product in order to establish a statistically relevant result. This approach proved not only costly, but -- in the final analysis -- unreliable, because a low level of contamination could still easily escape detection.[4] Bauman's solution was to design safety into the processing stage of processed food production. The solution was so effective that HACCP was adopted by NASA so that the astronauts would not be put at risk of food-borne illness in space.

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