Let’s not forget the Hazard Analysis and Critical Control Points system — HACCP — what it is, why it was developed and what its role truly is in regard to food safety.  HACCP was developed in the 50s because the food safety experts knew that you could not “test” food safety into food.  It was understood at that time that HACCP, coupled with strong hazard interventions was and continues to be the most effective way to produce safe food. HACCP was used very effectively by the canned food and ready-to-eat industry to produce safe food products.  

We all know what happened after the ground beef E. coli O157:H7 outbreak in 1993.  USDA and the food industry began the rapid movement toward mandatory HACCP.  It was obvious in 1993 that the voluntary approach to HACCP was not working — less than 5% of the meat and poultry industry had implemented HACCP.  During the early stages of the mandatory implementation there was much confusion within the government and the industry.  Almost all of the HACCP expertise resided in the ready-to-eat and canned food sectors.  Neither FSIS, USDA nor the raw side of the meat and poultry industry had sufficient knowledge about HACCP and this was the reason for the formation of the International HACCP Alliance in 1994–to standardize how we trained personnel in the HACCP arena.

I believe that, as mandatory HACCP was implemented, some key errors were made. We began going down two paths, which are actually contradictory to one another. One path is HACCP, with its effective interventions coupled with science-based validation systems, while the other path tries to “test” food safety into food. The second path essentially ignores the key reason that HACCP was developed. It will be impossible to overcome the tremendous problems associated with sampling food that contains non-uniformly distributed bacteria. The sample size would have to be so large that it would be unrealistic to sample sufficiently and have a high probability of finding the pathogen if it is present.

By forcing the meat and poultry industry to go down both paths, we have diverted huge resources to the wrong type of testing and away from the development and implementation of more effective farm-to-market interventions. The industry should be applauded for what it has accomplished over the past 17-18 years. Just think what could have been accomplished if the end product testing resources were used to produce safe food. Don’t let me give you the impression that all testing is not effective. Every HACCP plan should include strong testing programs to “validate” the interventions used in the HACCP plan.

So now we are about to have six more adulterants. We still do not know the true risk of the six Shiga-toxin producing E. coli – STECs – nor do we have proven tests to be used in a commercial setting.  So, my regret is that we continue to go down the “non-science” based path that will divert resources that could be used to produce safer food.


Dr. H. Russell Cross has more than 35 years of management experience, holding numerous positions in government, academia, and the private sector. Dr. Cross currently is Professor and Interim Head in the Department of Animal Science in the College of Agriculture and Life Sciences at Texas A&M University. He most recently served as Executive Vice President for Operations and Chief of Staff. His service in government included the role of Administrator of USDA’s Food Safety and Inspection Service under Presidents Bush (41) and Clinton. Dr. Cross also pioneered the International HACCP Alliance, serving as its founder and Executive Director. The International HACCP Alliance represents 24 food associations, 40 universities and the governments of 13 countries.