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The Potential Consequences of Public Release of Food Safety and Inspection Service Establishment-Specific Data

The Potential Consequences of Public Release of Food Safety and Inspection Service Establishment-Specific Data

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Published by: earthandlife on Nov 30, 2011
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12/01/2011

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T
he FoodSafety andInspectionService is theregulatory agencywithin the U.S.Department of Agriculture (USDA)that is responsiblefor ensuring thesafety, wholesome-ness, and proper labeling of meat, poultry, and processed egg products produceddomestically or imported into the United States.The Service does this by issuing and enforcingfood-safety regulations, conducting facility and product inspections, responding to foodbornedisease outbreaks, and conducting communica-tion, education, and food-defense activities.During the course of its testing, sampling,inspection and enforcement activities, the FoodSafety and Inspection Service collects largevolumes of food safety data, some of which aremade publicly available on its website. However,most of these data are aggregated, for example by geographicregion, produc-tion type,establishmentsize, and pathogen, and inmost cases thereis insufcientinformation provided to link data to specicfood industryestablishmentssuch as slaughter-houses,warehouses, or retail stores. While the public can obtain somedisaggregated data through the Freedom of Information Act, initiating and responding toFreedom of Information Act requests can betime-consuming and costly for the requester and the Food Safety and Inspection Service.In recent years there have been efforts tofacilitate openness in government, includingan administration requirement for federalagencies to publish information online in atimely manner and in a format that can beeasily retrieved, downloaded, and indexed by
The release of food safety data gathered during federal inspections of meat, poultry, and eggproduct processing establishments such as slaughterhouses, warehouses, and retail storeswould help increase transparency and could lead to improvements in public health. Forexample, purchasers, consumers, and public interest organizations could use the data toidentify companies with performance records consistently above or below the industryaverage, potentially creating economic pressure on food processing establishments to improvefood safety. However, in order to maximize its effectiveness and minimize unintended adverseconsequences, data release should be guided by a carefully designed information-disclosurestrategy.
The Potential Consequences of PublicRelease of Food Safety and InspectionService Establishment-Specic Data
©iStockphoto.com/Juanmonino
 
Provide incentives to food processing establish-ments to protect brand reputation in food safetyin order to protect and enhance customer baseand protability
Allow downstream users (purchasers, consum-ers or public interest organizations) to identifycompanies with performance records consis-tently above or below the industry average, potentially creating economic pressure toimprove food safety
Provide better insights into strengths andweaknesses of different processing practices,leading to industry-wide improvements in foodsafety practices
Enhance performance benchmarking by indi-vidual companies, sectors, and the industry as awhole, including efforts by individual companiesseeking to avoid being identied as “belowaverage”
Improve the consistency of inspector  performance
 Potential Costs and Unintended AdverseConsequences
Evidence of adverse effects resulting from the public release of establishment-specic data by other government agencies is insufcient to predict whatmight occur were the Food Safety and Inspectionthe public without the need for Freedom of Information Act requests. As part of these efforts,the Food Safety and Inspection Service is nowconsidering providing access to the data in adisaggregated form, giving the public access tofood safety data collected from specic foodindustry establishments.
Experience with Public Posting of Government Data
The concept of publicly posting government-generated data is not new. In response to calls for increased transparency and information provision,several government agencies, including regulatoryagencies responsible for protecting human healthand safety, now regularly post detailed data on theInternet. In some cases, the data relate to indi-vidual rms or facilities (for instance, Medicare publishes data on hospital-specic outcomes of care), while in other cases they are commodity, product, or event specic (for example, the National Highway Trafc Safety Administration posts data on safety ratings of products such as cars,tires, and children’s car seats). There is a substantial body of literature documenting the impacts and usesof publicly released data, showing that public accessto facility-specic performance data can have both benets and costs.
Public Release of Food Safety and InspectionService Establishment-Specic Data
The previous experiences of other federal agen-cies that have released detailed data can help predictthe potential benets and adverse impacts of postingestablishment-specic data collected by the FoodSafety and Inspection Service.
 Potential Benefts
At the most basic level, the public release of FoodSafety and Inspection Service establishment-specicdata would increase transparency by supporting the public’s “right to know,” and providing improvedinformation to support decision-making. Releasingthese data could potentially motivate individualcompanies, and sectors of the food industry, toimprove their overall food safety efforts. For example, data release could:
A worker packages ground beef in a meat processing plant.
©istockphoto.com/alle12
 
Service to release similar data. In the absence of information specic to the Food Safety andInspection Service, the Committee identied anumber of potential costs or unintended conse-quences that public release of establishment-specicdata might have, including:
The nancial commitment associated withdesigning and maintaining a useful data disclo-sure system
Drawing of inappropriate conclusions as a resultof misinterpretations of the data, particularly if appropriate context is not provided to the use
Adverse effects on international trade
Risks that proprietary or condential informa-tion could be deduced from the data
Adverse effects on inspector performanceIt is important to note that, as with all regulatoryinterventions, some parties may be negativelyimpacted by public data disclosure. Furthermore,different parties may have different perspectives onwhat constitutes a negative impact. In fact, a nega-tive impact for one party might be viewed as a positive effect for another, or may be considered positive by the public at large. For example,although company might suffer initial reductions inthe stock market prices following the release of data by the Food Safety and Inspection Service, ulti-mately this might serve as an incentive for improved performance, constituting a benet for the public.
Considerations for Strategic Planningfor Data Release
To maximize effectiveness and minimizethe potential for adverse unintended conse-quences, data disclosure needs to be guided bya carefully designed information disclosurestrategy. The disclosure strategy wouldconsider the utility of the data to be released,the presentation of data, and the means bywhich to assure that data are continuouslyupdated and improved. Key features of aneffective information disclosure plan include:
Assuring the integrity of the data, for example by requiring the development of  protocols to ensure the data are accurate,timely, and likely to be useful before posting
Providing precise and appropriate denitions of what is being quantied and adequate documen-tation of context, in order to limit the potentialfor misinterpretation of data
Providing support for analyses of the data byusers. At a minimum, this would involve releas-ing data in machine-readable form to facilitatethird-party analysis
Providing precautionary measures to prevent thelinking of portions of the data in ways thatwould allow the user to deduce condentialinformation about particular establishments.
Seeking input from stakeholders—for example,from industry, academia, and consumer groups— to provide insight on their needs andconcerns for all data types. This would facilitatecontinuous improvements in data disclosure asusers gain a better understanding of how thedata might be used, and as the Food Safety andInspection Service responds to stakeholder inputThe Committee examined the issues specic tothe public release of two specic types of FoodSafety and Inspection Service establishment-specicdata: Sampling and Testing data (derived usingstandard laboratory tests), and Inspection andEnforcement data (derived from text written byinspectors). The Committee believed that Samplingand Testing data are amenable to public release aslong as the key features described above areadequately addressed.
A supermarket meat display.
©istockphoto.com/luoman

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