Some Tips For The Tea Party

I’ve been challenged to find some policy planks for the Tea Party that would reduce the cost of federal food safety enforcement without putting the public at (greater) risk.

Here are a few thoughts, drawn from more than three decades of working in food safety.

Consolidate the food safety enforcement arms of FDA and USDA (Food Safety and Inspection Service). This would eliminate duplication of overlapping lab facilities and inspection programs. As a bonus, food companies now dealing with two separate federal agencies would only need to deal with one.

Require every shipment of imported ingredient, raw food or processed food to be accompanied by a Certificate of Analysis from an accredited laboratory. The cost would be paid for in toto by the off-shore producer and/or the importer – NOT by the US government. Domestic food processors must pay for their own lab tests. So should importers.

Eliminate the 100% inspection of federal meat plants. These resources can be spread more evenly throughout the newly consolidated agency, and increase overall food safety enforcement without increasing costs.

Eliminate HACCP mandates for the food industry. Motorists are told what speed limit they must observe – NOT how to observe it. Likewise, food producers and processors should be told what food safety standards they are expected to achieve. How they achieve these standards should be left to each individual company. As long as the standards are met, the way in which they are achieved should be irrelevant.

Privatize non-safety activities, such as USDA’s egg grading service. Last year’s shell egg-related outbreak of Salmonella Enteritidis demonstrated all too clearly that this is not looked upon by USDA as a safety function. Producers should be responsible for arranging – and paying for – activities such as shell egg grading.

I’m sure that there are more good ideas floating around in the blogosphere. I welcome your comments and rebuttals, and will be happy to post alternative suggestions.

5 thoughts on “Some Tips For The Tea Party

  1. Thanks very much for a thought provoking list!

    I applaud you effort to include the Tea Party in the food safety discussion. Unfortunately, key supporters of increased food safety regulation (e.g., Bill Marler and Marion Nestle) demonized them during the debate over the FDA Food Safety Modernization Act (FSMA).

    As I actively assisted 2 national tea party groups’ efforts to understand the FSMA via long blog discussions during the run up to the FSMA’s passage, I can testify to that many tea party participants were trying hard to understand the import of the various versions of the proposed FSMA—a very complex bill.

    I see a problem for #2 in that I expect the WTO would rule it is an unequal requirement; therefore, a trade barrier.

    I particularly like #4 because LEGISLATED HACCP IS NOT HACCP. This has been being pointed out since, at least, December 2002 when Dr. Bill Sperber shined a bright light on it in his presentation, “HACCP does not work from Farm to Table” at the 5th International Noordwijk Food Safety and HACCP Forum. Unfortunately, this paper is not readily available. As a result, I will send a digital copy of his paper to anyone who requests it by writing to me at

    Please clarify, Ms. Entis, whether or not you intend policy plank #4 to include elimination of the Hazard Analysis Risk-based Preventive Controls (HARPC) plan requirements (a variation of HACCP) recently mandated by the FSMA.

    In this instance, Congress also foolishly mandated HARPC plans for food facilities that do ZERO processing [packers and holders (i.e., storage facilities)] and, thus, have ZERO true “critical control points,” as defined by HACCP. The FSMA imposes on every food facility this variety of formal risk management that is appropriate in only very limited circumstances. As well documented by Community Involved in Sustaining Agriculture (CISA) in its ground breaking study, “HACCP for Salad Greens,” the cost of actually applying a plan is way too expensive for even many mid-sized facilities (see

    I would add another policy plank, “Repeal the new Sec. 419 Standards for Produce Safety of the Federal Food, Drug and Cosmetic Act.” This is another, new, additional requirement of the FSMA, the cost of which was grossly underestimated by the GAO. It extends the authority of the FDA from food to crops standing in fields. The FDA does not have the expertise to write the required regulations. In fact, no one does. The Good Agricultural Practices (GAP certification) which will be their foundation were initiated by and have always been under the USDA and state departments of agriculture. In addition, as Dr. Sperber showed in the paper cited above, this type of regulation foolishly over generalizes and thus misapplies the principles of HACCP.

    I hope that your ideas will provoke a genuine debate that is not derailed by trolls.


  2. Publish a dictionary of risk for all products where the risk is known. I always make it a habit to ask speakers who claim that a product is safe – how unsafe is safe and then try to define the known risk. For example our government proudly proclaimed in 2000 that the food supply is safe at the same time as the official stats went from 2 million cases and 30 deaths annually to 11 to 13 million cases and 500 deaths microbial foodborne disease in Canada – in dead, how safe is safe? How much truthiness should officials be allowed to spread before they too are liable?


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