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Saturday, 19 November 2011

A Modest Proposal:

Posted by Robert A. LaBudde, PhD, PAS, Dpl. ACAFS as part of a Foodsafe group discussion on the topic:

"The US Cannot Afford Food Safety Says AMI"

According to Dr. LaBudde: 

If every one believes regulated food safety is beneficial, and
everyone also believes that processors will pass "users' fees" on to
the consumer, then the obvious simple plan is this: Impose a tax
directly on food, with the proceeds directed to regulation.

This proposal will make the arguments of both sides much more
intelligible. Would consumers accept a 0.5% sales tax on food, in
order to get regulatory efforts to make food safer (a different thing
from food actually being safer)? Or would they prefer no tax and the
status quo?

Users' fees are objected to by industry because they are a
sleight-of-hand way of imposing a tax without going through Congress
or paying the political price of raising taxes and bloating
government. This is a valid point for their lobbyists, but is
somewhat irrelevant to food safety.

The real issue here is this: Will beefing up Federal regulation
actually make food safer, and will the benefit exceed the cost?

With local restaurant inspection, there have been numerous studies
and endless argument, with no proof that a measurable impact on food
safety occurs. Undoubtedly the reason is that politics intrudes any
regulation and castrates it, leaving it ineffective.

FDA will just hire more HQ workers and write more paper regulations.
I doubt if they will change their character and switch to frequent audits.

FSIS has already tried the large manpower + continuous inspection
approach, and found it valuable for food safety, but insufficient for
microbial hazards. They then tried HACCP, which every has to use, but
they then cheat in the details, so it also has had some benefit, but
does not solve the enforcement problem. FSIS has in the last few
years tried in-depth technical audits on-site, and this has proven
very effective, at least for a few months after.

What are the costs? What are the clear benefits? How will the costs
and benefits be compared to show success?

I personally believe this issue is similar to the one of police and
crime: There is no simple, permanent answer. More money on police
reduces crime somewhat, but does not exterminate it. After a few
years, the effect goes away as the enforcement system corrupts.
Eventually the police become the problem, not the criminals.

It is also similar to the endless exhortations of the next, new
'Quality' bandwagon that has occurred every 5 years since WWII. Or
in-plant safety programs. Etc.

What we really need is to get rid of the criminals by rehabilitation
programs. I believe the best use of new expenditures is to finance
local clerics at upscale places of worship to give regular sermons on
the evil of hurting one's neighbors in order to feather one's own
nest. And required continuing education in morality for food company
executives, who are the source of the problem.

With any crime, it is a 0.1% minority who keep it going. The
'habitual' criminals. This is true in drugs (users), prostitution
(Johns) and gambling. It is also true in food production. Either
rehabilitate these executives or extirpate them. Educate middle
management that "I was only following orders!" is equivalent to "The
dog ate my homework!", and they are accomplices to the mayhem and
manslaughter their actions cause.

Robert A. LaBudde, PhD, PAS, Dpl. ACAFS  Least Cost Formulations, Ltd.:


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