Happy Birthday, HACCP

Sept. 2, 2021

Thoughts on the 25th anniversary of Hazard Analysis of Critical Control Points.

This summer marked the 25th anniversary of HACCP, the concept that changed how food safety is enforced – indeed, how it’s thought of – in American food plants.

To run through it quickly, HACCP basically gave food processors a lot more of the responsibility for developing and overseeing safety issues. The theory was that by identifying the critical control points (CCP) of a process through hazard analysis (HA), and systematically monitoring them, a company could reliably turn out safe product.

When the USDA’s Food Safety and Inspection Service finalized the HACCP rule in 1996, it was touted as a more flexible approach to food safety. “Establishments have more flexibility to innovate and make establishment-specific decisions to improve food safety,” according to an FSIS news release. Before, companies had been operating on a “command-and-control” model, which basically meant counting on the FSIS inspector to catch problematic birds before they made it out the door. Putting the company more in charge of safety would be more effective – so the thinking went.

But there was another motivation for HACCP. It played into two strong political impulses: saving tax money and reducing regulation. Both were accomplished by cutting the number of FSIS inspectors – in effect, telling processors to inspect themselves.

To hear USDA tell it, HACCP has been a great success. They have numbers to back this up. According to a study cited in the FSIS release, salmonella contamination on chicken broiler carcasses decreased 56% from 1995 to 2000; the number of foodborne illness cases attributed to salmonella in broilers was 190,000 lower in 2000 than in 1995.

Except I’m wondering how much of that improvement is attributable to HACCP, as opposed to a more general increase in attention to food safety. The need for such attention became clear after a horrific food-poisoning incident in 1993 killed four children. That was one of the main drivers for HACCP, but it sparked broader overall consciousness of safety issues. Pathogen testing became more effective and more widespread, cleanability started becoming a central factor in equipment design, and other aspects of industry operations improved from a food safety standpoint. It’s impossible at this point to determine how much of the improvement in safety can be ascribed to HACCP alone.

This is more than an academic argument. HACCP has been used as a model for deregulation, or slackening regulations, around other aspects of food safety, most notably line speeds. The USDA under Trump proposed to increase speed limits on poultry processing lines from 140 birds per minute to 175; the Biden administration reversed that. It also declined to appeal a federal judge’s ruling against removing speed limits for pork processing lines entirely.

I think the Biden administration’s caution is the right approach. With staffing hard to come by, it’s a challenge for the industry just to keep up with production quotas. Asking it to take on more responsibility for food safety is just asking for trouble. Before we reduce the role of government in food safety any further, let’s be sure that there’s a payoff – and not just for the processors.

So happy birthday, HACCP. Only I’m not sure if there will, or should, be any happy returns.

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