Though the meat-processing industry and regulatory agencies frequently find themselves at odds, both groups want exactly the same thing: a safe food supply. The arguments arise when it comes to making it happen. Processors may want to incorporate new technology, either at the plant or upstream with the live animals, but the USDA may not be ready to approve those measures. FSIS may decide that more regulations or an overhaul of existing regulations may be the answer, but the industry sees only more costs and added regulatory burdens, with precious little gains in food safety.

Unfortunately, that’s where the industry stands at the moment. FSIS has issued a Draft Guidance on HACCP Systems Validation. This proposal would require companies to conduct in-plant testing to verify that their HACCP systems do what they say they do, instead of allowing a company to refer to established scientific resources.

If a company has a beef slaughter operation, FSIS estimates it will require 78 microbial tests to validate the plan. If it slaughters other animals, that’s an additional battery of tests. If it produces a variety of products, there could be a series of tests for each product. Along with the initial costs, there will be the costs for on-going verification.

The added costs to the processors could drive many smaller companies out of business, and the companies that are left will have to absorb those costs or, more likely, pass it further downstream. Eventually, that will result in higher prices for food, at a time when consumers are having a hard enough time making ends meet.

With all the conventions I’ve attended in the industry, the one consistent message I’ve heard is that lab tests are a measure of the effectiveness of food safety programs and are not meant to be a food safety program.

Furthermore, this comes at a time when the Centers for Disease Control and Prevention show that food-borne illnesses are actually decreasing in the U.S. Illnesses from E. coli O157:H7 are at a five-year low. Illnesses from Listeria monocytogenes rose slightly in 2009 but are still significantly lower than 2000, when HACCP regulations were implemented. Does this sound like a system that’s broken and in need of such a dramatic overhaul?

Given the unclear messages from FSIS about the purpose of this HACCP revision, you have to wonder if it’s a knee-jerk reaction to the bad press the processing industry has received this year. It’s a signal to the world that the FSIS is doing something about food safety — it may not be particularly practical or beneficial, but it’s something.

FSIS has been accepting comments about the proposal. The deadline for submitting a comment is June 19. Comments can be e-mailed to DraftValidationGuideComments@fsis.usda.gov or mailed to the Docket Clerk, USDA, FSIS, Room 2-2127, 5601 Sunnyside Ave., Beltsville, MD 20705.

It’s critical that as many processors as possible speak up and deliver a strong, unified message. Everyone wants safe food. Adding repetitive testing and driving small companies out of business is not the way to do it.