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.

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Robert A. LaBudde, PhD, PAS, Dpl. ACAFS  Least Cost Formulations, Ltd.: http://lcfltd.com/

Appointed National Coordinators

The GCSE-Food and Health Protection Team is pleased to announce the appointment of Monica Carcedo as the National Coordinator for Spain and Dr. Kakha Nadiradze as the National Coordinator for the Southern Caucasian Countries (Armenia, Azerbaijan and Georgia). Their roles include giving oversight to the activities of GCSE-FHP and serving as the national contact for regional coordinators in their respective countries.

If you are from these countries, you may send inquiries addressed to these representatives via the GCSE-FHP web site “Contact Us” link: http://www.afisservices.com/gcse-fhp/gcseinquiry.html

Curriculum Development Guide for the GCSE-Food & Health Protection Consumer Protection Training Program:

If you wish to be approved as a training provider, the guide for developing your curriculum is now available. It outlines the background understanding, the requirements for approval as a training provider, general aspects that the course must cover, the content of the submission package for approval, etc.

The guide is available to members of GCSE-FHP and your certificate # is your user name. You need to request a unique password that gives you access to the guide. You may send an email directly to the GCSE-FHP Team or use the online “Contact Us” link below to request your pass word. Please provide your membership certificate number in your request.

Contact Us : http://www.afisservices.com/gcse-fhp/gcseinquiry.html

GCSE-FHP Consumer Protection Training Program - The Benefits to the Various Groups:

Training providers – benefit from their participation

Trainees – benefit through acquired certification

Trained and Certified Personnel – benefit in their employability and through the ready access to information from GCSE-FHP for ongoing professional development

Practicing Industry Professionals - benefit from an expanded scope of professional engagement

Organizations – benefit from the assistance provided by GCSE-FHP in the development of their training programs

Employers – benefit from the readily available pool of trained and committed employees

Consumers – benefit from the acquired knowledge and the empowerment to be actively engaged in ensuring that products are safe

To learn more about the training program and how you can take advantage of its benefits to you, please contact the GCSE-FHP Team:  http://www.afisservices.com/gcse-fhp/gcseinquiry.html

Summary of Roles Performed by National & Regional Coordinators:

The national or regional coordinator role is open only to approved “Panellist” members of GCSE-FHP. Only one national coordinator can be appointed per country but several regional coordinators may be appointed. Each appointee performs the coordinator roles as a volunteer in the assigned jurisdiction.

National Coordinators:
• Oversee the activities of GCSE-FHP at the national level in the assigned country
• Understand and promote the GCSE-FHP campaign
• Promote the GCSE-FHP training on the principles and practice of consumer protection
• Advise GCSE-FHP on developments in the assigned country
• Lead GCSE-FHP initiatives
• Encourage and direct new members to register with GCSE-FHP
• Assist with the organization of campaign conferences in their jurisdiction
• Assist GCSE-FHP with the identification of regional divisions
• Serve as the national contact for regional coordinators as applicable
• Other contingent or evolving roles

Regional Coordinators:
• Understand and promote the GCSE-FHP campaign
• Promote the GCSE-FHP training on the principles and practice of consumer protection
• Oversee the activities of GCSE-FHP
• Advise GCSE-FHP on developments in the assigned region
• Lead GCSE-FHP initiatives
• Encourage and direct new members to register with GCSE-FHP
• Assist with the organization of campaign conferences in their jurisdiction
• Work with the national coordinator as applicable
• Other contingent or evolving roles

For additional information, please contact the GCSE-FHP Team: http://www.afisservices.com/gcse-fhp/gcseinquiry.html