But applying HACCP to raw food processing, where there is no such critical control point or kill step to eliminate pathogens, is an unscientific fraud perpetrated by those with agendas other than food safety. In the early nineties, HACCP was mandated for all raw meat and poultry slaughter and processing plants by the current Food Czar Michael Taylor, a former King & Spaulding lawyer for Monsanto who would go on to become its Vice President of Public Policy. The maneuver, a politically-based policy masquerading as a science-based measure, succeeded in privatizing the meat inspection process for large-scale plants and hyper-regulating small- and medium-sized plants out of business.
The regulations Taylor crafted limited meat inspectors authority to reviewing paperwork compiled by company employees at company-designated critical control points and eliminated inspectors' authority to pull obviously contaminated meat from anywhere on the assembly line. These changes allowed contaminated meat out the door with the USDA seal of approval. If that contaminated meat was later discovered, smaller downstream processors were left accountable for problems caused by the original slaughterhouses.
Twelve years later, the USDA's Food Safety and Inspection Service (FSIS) is calling for more microbial testing at downstream plants, an admission that the FSIS-style HACCP system regularly allows substantial amounts of contaminated meat shipped into commerce. This development has led the Ranchers-Cattlemen Action Legal Fund, United Stockgrowers of America (R-CALF) to call for FSIS-style HACCP to be abandoned or revamped.
Expected Collateral Damage
Economists who have analyzed the costs associated with implementing HACCP plans consistently and clearly state that the costs are significant. In "The Economic Implications of Using HACCP as a Food Safety Regulatory Standard," Laurian Unnevehr and Helen Jensen write that "The fixed costs of adding control technologies and for HACCP training may be prohibitively large for small firms. Thus its mandate may pose a greater burden on small firms, and lead to further concentration in the processing industry. Some observers have suggested a need for public education directed towards small firms. Others have suggested that there are operating efficiencies to be gained once HACCP is in place, through better organization of labor or processes (Mazzocco, 1996; Henson, et. Al., 1998) which small firms could capture if they overcome initial adoption costs. However, it is clear that there are economies of scale in human capital needed to implement HACCP, and thus its imposition will favor large firms." 
The authors note that mandating HACCP not only leads to greater food industry concentration, but that "HACCP regulations may also create incentives for greater vertical coordination to control food safety throughout the production process." 
In an article entitled "HACCP in small companies: benefit or burden?" Eunice Taylor writes that "Practical experience and a review of food safety literature indicates that success in developing, installing, monitoring and verifying a successful HACCP system is dependent on a complex mix of managerial, organizational and technical hurdles. In coping with this set of interrelating factors, even the largest food companies, equipped with significant resources of money, technical expertise and management skills may face a difficult challenge; the small company may feel that the difficulties of HACCP are potentially insurmountable." 
Trained personnel are key to successful HACCP plans. Eunice Taylor points out that "In large companies, the training and technical departments often lead the HACCP project: most small companies do not have these resources. It is evident therefore that even if owner-managers can be convinced of the necessity of HACCP, the allocation of sufficient "time' for its development becomes a major constraining factor. This is compounded by the requirement for specific HACCP training and the need to access the necessary technical expertise" To the small business this translates into a heavy financial burden and most owners look to Government or other agencies for external help at minimal costs." 
In a 1996 presentation on "Improving Cost/Benefit Analysis for HACCP and Microbial Food Safety: An Economist's Overview," Laurian Unnevehr and Tanya Roberts discuss how HACCP costs are not only substantial but that economies of scale directly benefit larger industry players. The authors explain that the costs of HACCP "include the costs of designing and implementing controls that achieve the standard for pathogen reduction. The array of control options available will vary with type of animal product and by type of changes required to control a specific pathogen. HACCP involves a large fixed investment to develop the plan and to train staff. It may also require new capital equipment. These fixed costs mean that there are economies of scale in HACCP. The variable costs are often minor in terms of labor and materials. Thus costs will vary by scale of plant, with implications for industry structure. A full accounting of costs would recognize process redesign. However, these generalizations may not hold for HACCP at the farm level, where variable costs could be more important." [26
The United Nation's Food and Agriculture Organization has also reviewed the economics of HACCP and is quite clear about HACCP's ability to drive small- and medium-sized business into bankruptcy: "HACCP rules mandated across an industry will have different impacts on the industry, depending on the market structure of the industry. In general, HACCP rules will likely impose higher costs on small firms than on large firms. An example of this is provided by estimates of market structure change on the United States meat and poultry slaughter and processing industry predicted to result from HACCP. Industry leaders predict that the regulation will drive small producers out of business. The actual effects on small producers will depend on the cost disadvantage faced by small firms, and the degree to which small plants can raise prices in the event they face a cost disadvantage. It will also depend on the ability of small plants to occupy small market niches that allow them to pass along higher product costs. For the United States meat and poultry industry, economists predict that if small producers do exit the industry, the pattern will be an increase in the rate of exits and decrease in the rate of entries." 
Other countries have had some experience with food safety laws being used as a pretext to destroy local food production and traditions. Speaking in India at a 2006 conference called "Beyond the Monoculture," Vandana Shiva tells how food safety laws are forcing people to globalize, a process that displaces their traditional foods. Shiva says that "the pretense of food safety has been another way of dismantling the local food economy." By claiming traditional ways of food production are "dangerous," laws have been passed that deregulate big industry and criminalize the methods of those trying to make an honest living.
Any Food Safety Reform with Teeth Doomed by Trade Agreements
The key to understanding why nothing in this legislation will make our food safer requires understanding the role of trade rules enforced by the World Trade Organization. Though ignored by the media, congressional representatives, senators and "Make Our Food Safe," the coalition of groups pushing the legislation, the inconvenient fact is that WTO rules specify adherence to the "equivalency" system. As explained byLori Wallach and Patrick Woodall of Public Citizen in Whose Trade Organization: A Comprehensive Guide to the WTO, "The WTO's terms contribute to these food-safety problems not only by leading to substantially increasing food trade, but by constraining governments' ability to address problems posed by foodborne illnesses. Not only have nations' food safety laws come under threat in the powerful dispute-resolution body of the WTO, but WTO rules embodied in the WTO Sanitary and Phytosanitary Agreement harm public well-being by encouraging an ongoing race to the bottom in food-safety standards." 
A 2007 report by Public
Citizen also warned of this problem.
In a report entitled "Trade Deficit in Food Safety: Proposed NAFTA
Expansions Replicate Limits on US Food Safety Policy That Are Contributing to
Unsafe Food Imports" the authors explained that "Trade rules contained in NAFTA, the WTO and incorporated
into the new FTAs pending before Congress forbid special safety requirements
for imports. Even though border inspections of imports may be the only
food safety check on imported foods relative to the domestic food safety system
which includes several levels of oversight, trade agreements
"non-discrimination" or "national treatment" rules require
that the United States not inspect imported foods at a greater rate than
domestic foods. Further, the trade agreements require the United States
to rely on foreign regulatory structures and foreign safety inspectors to
ensure that food imports are safe. This includes rules that obligate the
United States to find the different -- perhaps less safe -- meat and poultry
inspection systems of importing countries to be "equivalent" to the
U.S. system, and then allow "free passage" of products from such