Introduction

The cost of a HACCP regulation for most industries will depend not only on the requirements of the regulation, but also on the current status of food safety-related practices of the plants in these industries. This paper reports the results of a survey that we conducted on behalf of the FDA to determine the current and projected status of plants with respect to HACCP and related food safety practices. Until now, very little information was available about food safety practices. Our paper sheds light on the degree to which different sectors of the food industry will have to change the way they do business to be compliant with a HACCP rule.

Approach

The survey was part of a larger study to determine the cost of prospective HACCP regulations for plants regulated by FDA. Plants producing seafood were not included in the study. The first step of the analysis was to determine the baseline level of compliance with HACCP and food safety-related practices. The second step was to determine the per-plant cost of making the changes required to implement these practices. The survey was designed to meet the objectives of the first step of the analysis.

Because HACCP is difficult to define, especially for such a broad industry, we constructed a survey instrument that asked industry about current practices with respect to HACCP training and implementation, sanitation procedures, and other food safety-related practices. The survey was customized for each plant interviewed based on the nature and complexity of the plant's operations.

Survey Procedures

The survey universe was defined by FDA's Official Establishment Inventory, a list of all the plants that are inspected by FDA. We stratified the sample by industry sector and company size, using the Small Business Administration's definitions of large and small companies. The total number of respondents was 595, for an overall response rate of 32 percent.

The survey was administered via telephone. In the recruitment phase, we identified a respondent in each plant and mailed the respondent information that would help him or her complete the telephone interview. In the interview phase, we collected the responses during a prearranged telephone interview.

Preliminary Results

HACCP Training and Implementation:

• Sixty-three percent of plants surveyed have employees who have received some kind of HACCP training. Employees of large companies are more likely to have had HACCP training and are more likely to rate themselves "very familiar" with HACCP.
• While 75 percent of plants owned by large companies have conducted a hazard analysis for at least one product, only 51 percent of plants owned by small companies have done so. Forty-four percent of all plants surveyed have written and implemented a HACCP plan for at least one product. Large companies lead small companies in HACCP plan implementation by 30 percentage points.
• Among plants owned by small companies, the animal products industry is leading the implementation of HACCP. Among plants owned by large companies, cereals/ grains/baked goods lead HACCP implementation.

HACCP Diffusion:

• HACCP diffusion has been relatively rapid since 1990 and had another surge of activity in 1994. It has slowed since 1996.
• While a significant number of plants plan to implement HACCP within the next year, about 30 percent of plants owned by small companies and 12 percent of plants owned by large companies say that they will never implement HACCP if FDA does not require it for their plant.

Sanitation:

• One of the costs of HACCP will be making sure that prerequisite programs such as sanitation programs are in place and functioning properly.
• Despite current Good Management Practices, only 71 percent of plants owned by small companies currently have a written sanitation program, and only about 73 percent of plants owned by small companies maintain records to verify sanitation inspections.
• The sensitive products, animal protein products, and cereals/grains/baked goods sectors lead in having sanitation programs.

Related Food Safety Processes:

• Plants owned by large companies lead plants owned by small companies in implementing most food safety processes. For example, while 86 percent of plants owned by large companies require written vendor guarantees of the specifications for raw materials and ingredients, only 67 percent of plants owned by small companies do so. We collected information about 105 food safety processes.

Concluding Observations

• The baseline adoption of HACCP in many industries is almost certainly being influenced by the promulgation of HACCP rules for other industries.
• Consequently, some industry segments are adopting HACCP faster than others are.
• Large companies are adopting HACCP at a higher rate than smaller firms are.
• In many cases, implementing HACCP will require more significant changes in plants owned by small companies.
• The process costs of HACCP are significant.

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