Recent cost benefit analyses accompanying the USDA meat and poultry and FDA seafood HACCP-based rules have received some criticism for the cost assumptions and hypothesized pathogen reductions upon which they were based. The cumulative and speculative nature of the cost data is inevitable and correct for the purpose of comparison against the similarly aggregated and forecasted benefits of the regulations. However, given actual cost data linked to plant-level hazard reductions some of these issues can be addressed retrospectively.

Unfortunately, such correlations are "catch-22" situations, with ex post results merely highlighting the inaccuracies of estimates made ex ante due to events that can only be observed post-implementation (e.g., which pathogen reduction strategies are adopted by firms and whether firms adopt HACCP solely due to a regulatory requirement). To be more useful such comparisons should be used to guide future regulatory impact analyses by indicating potential biases in current assumptions and methodologies. In order to complete such a role it is necessary to have representative, detailed cost data which can be linked to actual food safety improvements solely due to the particular strategy or HACCP-based system under review. Such marginal analysis was the focus of the two papers discussed here.

Jensen and Unnevehr estimate the minimal costs of attaining a range of pathogen standards for large pork slaughter plants. The methodology highlights that if (and perhaps only if) such selections are made on a least cost basis then actual process modification costs may be lower than suggested in the USDA rule. When the study can be expanded to include a full range of interventions and extended to cover beef and poultry slaughter and processing a more complete comparison to the USDA rule can be made. This will have to pay close attention to adoption rates for each strategy.

Jensen and Unnevehr present a clear framework for incorporating pathogen reduction data into their assessment of least-cost interventions. However, one needs to be very careful in applying these microbiological results. An honest and open approach that identifies the weakness of the underlying microbiological data is best. This is especially true when discussing the effectiveness of these interventions for risk versus hazard reduction. Although it takes a major step forward, bringing together microbiological and economic data, the paper also requires several caveats to be considered before one can apply such a model to plant-level data.

Colatore and Caswell present a detailed case study of the costs of adoption of HACCP for the breaded fish sector. The value and selection of this group of firms must relate to its representative nature within the industry for a fair comparison to the FDA estimates. The authors provide an excellent analysis of the motivation for adoption and final coverage of the HACCP plans surveyed. However, care needs to be taken. Clearly they found that many of the seafood processors implemented HACCP before required to do so by FDA. It is not clear though how many processors pre-positioned themselves and became ‘first-movers' in preparation for the rule. Should all of their HACCP-related expenditures be considered compliance costs or merely the costs of ensuring their ‘quasi-voluntary' HACCP plans conformed to the mandated system?

Several potential indirect impacts may be considered in the broader economic analysis of HACCP-based regulations:

• Scale - as HACCP-based regulations expand in their coverage (e.g., to the retail sector with many small and very small firms) it is argued that plant or firm size will be of paramount importance.
• Joint products - The food safety system put in place by a plant can also impact non-safety quality attributes, thus increasing overall efficiency. This result was found by both Jensen and Unnevehr and Colatore and Caswell.
• Reducing variability - HACCP plans limit product rejection or rework reducing the variability inherent to all production processes. This benefit allows for increased customer/consumer satisfaction, reduced complaints and product return, and may increase difficult to quantify measures of consumer confidence.
• International trade - is clearly facilitated when an ‘harmonized' HACCP-based regulation is in place.
• Legal liability - and insurance cost savings can arise from the use of innovative food safety controls. A first-mover advantage may be achieved. This can improve the overall company image, potentially providing a competitive and marketing advantage when such channels exist.

Such impacts may or may not be candidates for inclusion in future analyses depending upon the details of the regulation.

The potential use of novel individual interventions, and innovative combinations of "traditional" interventions, clearly make the ex ante estimation of costs and benefits extremely difficult. It seems likely that the future role of pilot programs to suggest real-world impacts will be expanded. Hopefully, these studies will utilize representative firms' experiences and consider all "state-of-the-art" interventions. Where not widely adopted in the industry special care must be taken when suggesting the impacts of any novel interventions, requiring judgements of their effectiveness based on plant-level experiences and not just laboratory assessments. At all times the effectiveness of novel interventions should be compared to current systems on a microbiological as well as a cost basis.

It would be wrong to presume that just because HACCP enjoys net benefits in one industry or sector that it will do the same in all mandated applications. The economics of HACCP will not always drive all assessments of the system. Given changes in current assumptions and methodologies it may be possible that a regulation can be proven to have no net benefit yet large food safety gains. Wether such a regulation is adopted depends upon the value placed by society on the individual components of the cost benefit analysis.

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