The Potential Consequences of Public Release of
Food Safety and Inspection Service
Establishment-Specific Data
Committee on a Study of Food Safety and Other Consequences of Publishing
Establishment-Specific Data
Board on Agriculture and Natural Resources
Division on Earth and Life Studies
NATIONAL RESEARCH COUNCIL
OF THE NATIONAL ACADEMIES
THE NATIONAL ACADEMIES PRESS
Washington, D.C.
THE NATIONAL ACADEMIES PRESS 500 Fifth Street, N.W. Washington, DC 20001
NOTICE: The project that is the subject of this report was approved by the Governing Board of the National Research Council, whose members are drawn from the councils of the National Academy of Sciences, the National Academy of Engineering, and the Institute of Medicine. The members of the committee responsible for the report were chosen for their special competences and with regard for appropriate balance.
This project was supported by Award AG-3A94-C-08-0018 Task Order 9/AG-3A94-D-10-0255 0255 between the National Academy of Sciences and the US Department of Agriculture Food Safety and Inspection Service. Any opinions, findings, conclusions, or recommendations expressed in this publication are those of the authors and do not necessarily reflect the view of the organizations or agencies that provided support for this project.
International Standard Book Number-13: 978-0-309-22465-9
International Standard Book Number-10: 0-309-22465-9
Additional copies of this report are available from the National Academies Press, 500 Fifth Street, N.W., Lockbox 285, Washington, DC 20055; (800) 624-6242 or (202) 334-3313 (in the Washington metropolitan area); Internet, http://www.nap.edu
Copyright 2011 by the National Academy of Sciences. All rights reserved.
Printed in the United States of America
THE NATIONAL ACADEMIES
Advisers to the Nation on Science, Engineering, and Medicine
The National Academy of Sciences is a private, nonprofit, self-perpetuating society of distinguished scholars engaged in scientific and engineering research, dedicated to the furtherance of science and technology and to their use for the general welfare. Upon the authority of the charter granted to it by the Congress in 1863, the Academy has a mandate that requires it to advise the federal government on scientific and technical matters. Dr. Ralph J. Cicerone is president of the National Academy of Sciences.
The National Academy of Engineering was established in 1964, under the charter of the National Academy of Sciences, as a parallel organization of outstanding engineers. It is autonomous in its administration and in the selection of its members, sharing with the National Academy of Sciences the responsibility for advising the federal government. The National Academy of Engineering also sponsors engineering programs aimed at meeting national needs, encourages education and research, and recognizes the superior achievements of engineers. Dr. Charles M. Vest is president of the National Academy of Engineering.
The Institute of Medicine was established in 1970 by the National Academy of Sciences to secure the services of eminent members of appropriate professions in the examination of policy matters pertaining to the health of the public. The Institute acts under the responsibility given to the National Academy of Sciences by its congressional charter to be an adviser to the federal government and, upon its own initiative, to identify issues of medical care, research, and education. Dr. Harvey V. Fineberg is president of the Institute of Medicine.
The National Research Council was organized by the National Academy of Sciences in 1916 to associate the broad community of science and technology with the Academy’s purposes of furthering knowledge and advising the federal government. Functioning in accordance with general policies determined by the Academy, the Council has become the principal operating agency of both the National Academy of Sciences and the National Academy of Engineering in providing services to the government, the public, and the scientific and engineering communities. The Council is administered jointly by both Academies and the Institute of Medicine. Dr. Ralph J. Cicerone and Dr. Charles M. Vest are chair and vice chair, respectively, of the National Research Council.
COMMITTEE ON A STUDY OF FOOD SAFETY AND OTHER CONSEQUENCES OF PUBLISHING ESTABLISHMENT-SPECIFIC DATA
LEE-ANN JAYKUS, Chair, North Carolina State University, Raleigh, North Carolina
JULIE A. CASWELL, University of Massachusetts Amherst
JAMES S. DICKSON, Iowa State University, Ames
JOHN R. DUNN, Tennessee Department of Health, Nashville
STEPHEN E. FIENBERG, NAS,1 Carnegie Mellon University, Pittsburgh, Pennsylvania
WILLIAM K. HALLMAN, Rutgers, the State University of New Jersey, New Brunswick
GINGER ZHE JIN, University of Maryland, College Park
GALE PRINCE, Sage Food Safety Consultants, LLC, Cincinnati, Ohio
DONALD W. SCHAFFNER, Rutgers, the State University of New Jersey, New Brunswick
KATHLEEN SEGERSON, University of Connecticut, Storrs
CHRISTOPHER A. WALDROP, Consumer Federation of America, Washington, DC
DAVID WEIL, Boston University, Massachusetts
Staff
CAMILLA YANDOC ABLES, Study Director
MARIA ORIA, Study Director
KATHLEEN REIMER, Senior Program Assistant
NORMAN GROSSBLATT, Senior Editor
____________________
1 National Academy of Sciences
BOARD ON AGRICULTURE AND NATURAL RESOURCES
NORMAN R. SCOTT, Chair, NAE,1 Cornell University, Ithaca, New York
PEGGY F. BARLETT, Emory University, Atlanta, Georgia
HAROLD L. BERGMAN, University of Wyoming, Laramie
RICHARD A. DIXON, NAS,2 Samuel Roberts Noble Foundation, Ardmore, Oklahoma
DANIEL M. DOOLEY, University of California, Oakland
JOAN H. EISEMANN, North Carolina State University, Raleigh
GARY F. HARTNELL, Monsanto Company, St. Louis, Missouri
GENE HUGOSON, Global Initiatives for Food Systems Leadership, St. Paul, Minnesota
MOLLY M. JAHN, University of Wisconsin-Madison
ROBBIN S. JOHNSON, Cargill Foundation, Wayzata, Minnesota
A.G. KAWAMURA, Solutions from the Land, Washington, DC
JULIA L. KORNEGAY, North Carolina State University, Raleigh
KIRK C. KLASING, University of California, Davis
VICTOR L. LECHTENBERG, Purdue University, West Lafayette, Indiana
JUNE BOWMAN NASRALLAH, NAS,2 Cornell University, Ithaca, New York
PHILIP E. NELSON, Purdue University, West Lafayette, Indiana
KEITH PITTS, Marrone Bio Innovations, Davis, California
CHARLES W. RICE, Kansas State University, Manhattan
HAL SALWASSER, Oregon State University, Corvallis
ROGER A. SEDJO, Resources for the Future, Washington, DC
KATHLEEN SEGERSON, University of Connecticut, Storrs
MERCEDES VAZQUEZ-AÑON, Novus International, Inc., St. Charles, Missouri
Staff
ROBIN A. SCHOEN, Director
CAMILLA YANDOC ABLES, Program Officer
RUTH S. ARIETI, Research Associate
KAREN L. IMHOF, Administrative Coordinator
KARA N. LANEY, Program Officer
AUSTIN J. LEWIS, Senior Program Officer
JANET M. MULLIGAN, Senior Program Associate for Research
KATHLEEN REIMER, Senior Program Assistant
EVONNE P.Y. TANG, Senior Program Officer
PEGGY TSAI, Program Officer
___________________
1National Academy of Engineering
2National Academy of Sciences
Preface
Public release of establishment-specific data is not a new concept for some federal and state regulatory agencies, but it is new to the Food Safety and Inspection Service (FSIS). Hence, FSIS will need to consider many issues, and it is our hope that this report will be of value as the agency pursues public data release in a manner that promotes transparency and ultimately results in improvements in public health. We suspect that our conclusions will also be relevant to other food-safety agencies as they move down the path of increasing stakeholder engagement through formal data-release programs.
I would like to thank the committee members, whose diverse expertise made for thought-provoking discussion. Their commitment to listening to the views of others and drafting a document that was both comprehensive and universally accepted is greatly appreciated. I would also like to thank FSIS personnel, who kept in contact with the committee over the course of deliberations, providing both formal and informal input regarding the structure of their current data systems and their vision for the future, which includes release of establishment-specific data. Likewise, representatives of the meat and poultry industry provided honest discussion with respect to their concerns and suggestions for future public data release.
Thanks also to the staff of the Board on Agriculture and Natural Resources and the Food and Nutrition Board of the National Academies, especially to study directors Camilla Ables and Maria Oria, for keeping the committee on task and coordinating deliberations and document review. Special thanks to Kati Reimer, who planned the meetings and facilitated communications, always with enthusiasm and a smile. Finally, I thank Robin Schoen, whose insights on study protocol helped us to produce a relevant consensus document. In short, whereas the committee provided the brain power, the staff was able to make that into something of value to the scientific and regulatory food-safety community at large. For that, I am deeply grateful.
Lee-Ann Jaykus, PhD, Chair
Committee on a Study of Food Safety and Other
Consequences of Publishing Establishment-Specific
Data
Acknowledgments
This report has been reviewed in draft form by persons chosen for their diverse perspectives and technical expertise in accordance with procedures approved by the National Research Council Report Review Committee. The purpose of the independent review is to provide candid and critical comments that will assist the institution in making its published report as sound as possible and to ensure that the report meets institutional standards of objectivity, evidence, and responsiveness to the study charge. The review comments and draft manuscript remain confidential to protect the integrity of the deliberative process. We thank the following for their review of the report:
Gina R. Bellinger, Food Safety Net Services
Dane Bernard, Keystone Foods, LLC
Jerry Bowman, Institute of Food Technologists
Christine Bruhn, University of California, Davis
James Hamilton, Duke University
Neal H. Hooker, St. Joseph’s University
Ian Jenson, Meat & Livestock Australia
William Keene, Oregon Public Health Division
Barbara Masters, OFW Law
Greg Paoli, Risk Sciences International
John R. Ruby, JBS USA, LLC
Although the reviewers listed above have provided many constructive comments and suggestions, they were not asked to endorse the conclusions or recommendations, nor did they see the final draft of the report before its release. The review of the report was overseen by Robert Gravani, Cornell University, and Elaine Larson, Columbia University. Appointed by the National Research Council, they were responsible for making certain that an independent examination of the report was carried out in accordance with institutional procedures and that all review comments were carefully considered. Responsibility for the final content of the report rests with the author committee and the institution.
Abbreviations and Acronyms
AERS | Adverse Event Reporting System |
AMS | Agricultural Marketing Service |
CDC | Centers for Disease Control and Prevention |
CSPI | Center for Science in the Public Interest |
CSV | comma-separated values |
ECHO | Enforcement and Compliance History Online |
EPA | Environmental Protection Agency |
FDA | Food and Drug Administration |
FOIA | Freedom of Information Act |
FOOD | Foodborne Outbreak Online Database |
FoodNet | Foodborne Diseases Active Surveillance Network |
FSA | Food Safety Assessment |
FSIS | Food Safety and Inspection Service |
HACCP | Hazard Analysis and Critical Control Point |
HTML | hyper text markup language |
IDEA | Integrated Data for Enforcement Analysis |
IICs | inspectors-in-charge |
IOM | Institute of Medicine |
LADPH | Los Angeles Department of Public Health |
MSHA | Mine Safety and Health Administration |
NACMPI | National Advisory Committee on Meat and Poultry Inspection |
NIH | National Institutes of Health |
NR | noncompliance record |
OMB | Office of Management and Budget |
OPEER | Office of Program Evaluation, Enforcement and Review |
OSHA | Occupational Safety and Health Administration |
portable document format | |
PDP | Pesticide Data Program |
PHIS | Public Health Information System |
PR | Pathogen Reduction |
RFR | Reportable Food Registry |
RTE | ready-to-eat |
TRI | Toxic Release Inventory |
USDA | US Department of Agriculture |
XML | extensible markup language |
Contents
The Food Safety and Inspection Service Regulatory Framework
2 TRANSPARENCY AND FOOD SAFETY AND INSPECTION SERVICE DATA-SHARING
Transparency and Disclosure of Data
Types of Data Collected by the Food Safety and Inspection Service
Uses and Users of Food Safety and Inspection Service Data and Data Sharing Efforts
The Role of the Food Safety and Inspection Service Public Health Information System
3 EXPERIENCE WITH PUBLIC POSTING OF GOVERNMENT DATA
Examples of Collection and Release of Data by Regulatory Agencies
Reporting of Food-Safety Data by Nonregulatory Agencies
Reported Effects of Releasing Establishment-Specific Data
4 PUBLIC RELEASE OF FOOD SAFETY AND INSPECTION SERVICE ESTABLISHMENT-SPECIFIC DATA
Possible Benefits, Costs and Unintended Adverse Consequences
Strategic Planning of Data Release
Considerations for Release of Food Safety and Inspection Service Establishment-Specific Data
List of Tables, Figures, and Boxes
TABLES
2-2 FSIS Enforcement Data that are Under Consideration for Establishment-Specific Release
2-4 Example of Establishment-Specific Salmonella Data under Consideration for Public Posting by FSIS
FIGURES
1-1 Diagram of the FSIS Regulatory Framework
BOXES
2-1 Types of Information that Cannot be Released through the Freedom of Information Act