The Potential Consequences of Public Release of Food Safety and Inspection Service Establishment-Specific Data (2011) / Chapter Skim
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4 Public Release of Food Safety and Inspection Service Establishment-Specific Data
4 Public Release of Food Safety and Inspection Service Establishment-Specific Data
Pages 53-70
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From page 53... ...
The purpose of this chapter is three-fold: to discuss the potential benefits and adverse consequences of releasing establishment-specific FSIS data; to present issues related to data release that FSIS may want to consider during the development of a strategic data-release plan, including approaches to measuring the public-health and other relevant effects of data release; and to present the committee's findings and conclusions regarding the public release of establishment-specific FSIS data.
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From page 54... ...
For example, data release could provide incentives to protect brand reputation in food safety and to protect or enhance customer base and profitability; allow downstream purchasers and consumers or public interest organizations to identify companies whose performance records were consistently above or below the industry average and potentially create economic pressure to improve food safety; provide better insights into strengths and weaknesses of different processing practices, which could lead to industrywide improvements in food safety practices; enhance performance benchmarking by individual companies, sectors, and the industry as a whole, including efforts by individual companies that are seeking to avoid being identified as "below average"; and improve the consistency of inspector performance. Even if individual firms do not change their behavior in response to data posting, overall food safety could improve if information about performance leads consumers to favor high performing establishments and hence causes a shift in the composition of the market.
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From page 55... ...
Public release of FSIS establishment-specific data could also lead to improved public understanding of the considerable efforts made by FSIS and the industry to ensure food safety. For example, if data release could be linked to specific improvements in food safety, it might promote public perceptions of and confidence in the safety and integrity of the food supply and in the companies and regulatory agencies that are responsible for ensuring them.
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From page 56... ...
Similarly, the agency would need to take precautions to avoid the possibility that portions of the data could be linked in ways that would allow users to deduce confidential information about particular establishments, such as FSIS inspection patterns, regulatory assignments, or sampling regimes. For example, FSIS may choose to release data on enforcement actions only after they have been completed, but real-time release of establishment-specific microbial-testing data could reveal that additional testing had been ordered for a particular establishment, which would indicate a new enforcement action.
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From page 57... ...
Because effective data release requires cooperation among FSIS, industry, and the stakeholders most likely to use the data, the development of the strategic plan would benefit from their input. And because data themselves evolve, as do their uses, FSIS may also want to consider the need for continuous improvements based on industry and user feedback and agency response to that feedback.
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From page 58... ...
The committee believes that this situation presents a strong argument for pursuing the broadest possible data release at the most disaggregated level. Users can always aggregate data for their analytic needs, but they cannot access disaggregate detail from aggregated data.
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From page 59... ...
, are reaching out to potential users to assist them in developing sites and "apps" that will improve the utility of data released to the public. 44 Providing Context for Interpretation Adequate context of how data were collected and their limitations is important for the use and interpretation of released data.
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From page 60... ...
These could be set up so that individual stakeholders could opt in to receive content or audience-specific alerts or could be sent to targeted audiences, such as key mass-media outlets, academics, industry, advocacy organizations, trade associations, and scientific societies. CONSIDERATIONS FOR RELEASE OF FOOD SAFETY AND INSPECTION SERVICE ESTABLISHMENT-SPECIFIC DATA Sampling and Testing Data FSIS routinely collects sampling and testing data on the foodborne pathogens E
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From page 61... ...
, FSIS usually provides public access to chemical and residue testing results as reports of aggregated data, sometimes with detailed statistical analyses, 48 See http://www.fsis.usda.gov/Science/Ecoli_O157_Summary_Tables/index.asp (accessed August 5, 2011)
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From page 62... ...
Industry representatives also cited considerable variation in FSAs. They expressed concerns that many FSAs relate to and reveal specific components of an establishment's HACCP system that are considered proprietary.
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From page 63... ...
Public access to NRs and FSAs may also place front-line inspectors under increased scrutiny not only by the industry and FSIS supervisory staff but by the public. Despite the subjective nature of FSIS enforcement data, the committee noted that inspector-based data are generated in many regulatory arenas and have previously been released to the public.
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. Thus, it is not now possible to measure directly the value of a public data-release program for improvements in food safety and public health.
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From page 65... ...
On the basis of a review of literature on the experience of other public agencies, the committee identified a number of potential benefits of public release of establishment-specific FSIS data, including providing incentives to protect brand reputation in food safety and to protect or enhance customer base and profitability; allowing downstream users to identify companies with performance records below and above the industry average and to create economic pressure to improve food safety; providing better insights into strengths and weaknesses of different processing practices, which could lead to industrywide improvements in food-safety practices; enhancing performance benchmarking; and improving the consistency of inspector performance. The committee concluded that public release of FSIS establishment-specific data, by themselves or in combination with other privately or publicly available data, could yield valuable insights that go beyond the regulatory uses for which the data were collected.
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From page 66... ...
For example, although the literature suggests that disclosure of information about the performance of a specific facility has the potential to affect the facility's profitability, it is precisely this possibility that creates an incentive for improved performance, which would constitute a benefit from the perspective of the public. On the basis of its review of information and its deliberations, the committee concluded that strong arguments support public release of establishment-specific FSIS data, especially data that are now subject to release through FOIA, unless there is compelling evidence that such release is not in the public interest.
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From page 67... ...
Although it is not possible to make a direct causal link between public data access and specific food-safety improvements, the committee concluded that measures of other outcomes of public release of establishment-specific data are available and that documenting those outcomes could provide insights into the relationship between data release and food safety. For example, public release of establishment-specific data could result in increased compliance with regulatory requirements, and FSIS could measure this.
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From page 68... ...
Accessed October 27, 2010. USDA/FSIS (United States Department of Agriculture/Food Safety and Inspection Service)
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From page 69... ...
Appendixes
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Key Terms
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