“A foolish consistency is the hobgoblin of little minds, adored by little statesmen and philosophers and divines,” said early-American philosopher and essayist Ralph Waldo Emerson.
But in the Office of the Inspector General (OIG) at the U.S. Department of Agriculture, consistency gets greater appreciation. In its recent evaluation of USDA’s Food Safety and Inspection Service equivalency assessments of exporting countries, the OIG seems to long for uniformity.
The FSIS is agreeable to most of the OIG’s recommended changes. Neither the audit report nor the FSIS responses mentioned any dollar figures for the added costs that might be involved.
The OIG findings include:
- Equivalent countries’ audits are not consistent.
- FSIS isn’t consistently auditing similar countries and policies.
- Procedures for selecting countries for ongoing equivalent verification audits are not being followed.
- FSIS doesn’t have adequate policies to monitor, classify, evaluated or determine equivalent sanitary measures.
- Nor does FSIS know when foreign establishments require removal from the equivalency program.
The OIG is also concerned about FSIS’s prior audit recommendations not including corrective actions.
The latest report is the third time the OIG has studied FSIS’s foreign equivalency assessments. In 2005, it looked at the FSIS examination of Canada’s inspection system. In 2008, the OIG focused on the adequacy of the FSIS inspection processes, including its on-site audits, and re-inspections of meat, poultry, and egg imports.
In the most recent study, the OIG reviewed FSIS findings that show exporting counties are consistent with U.S. standards and that foreign systems remain equivalent.
The report found FSIS “has a robust system for determining initial equivalence” and the OIG “found no public health concerns related to FSIS’ ongoing equivalence.”
However, the OIG found “a weakness in the agency’s oversight structure for monitoring equivalence.” It said FSIS’s performance assessment is not consistent and it lacks management controls.
“Without more robust controls over ongoing equivalence evaluations of foreign countries’ food safety systems, we concluded that FSIS’ inspection program is vulnerable to weaknesses that increase the risk of adulterated or unsafe meat, poultry, or egg products being imported into the United States,” according to the OIG report.
The OIG report opines about the need for a variety of revisions, including better tracking of verification audit scheduling; better documentation policies and procedures for equivalence verification audits; better plan and systems for monitoring once equivalence is recognized; and the need for a policy for delisting a country’s status.
The formal recommendations include:
- Develop and document the method for selecting countries for equivalence verification audits.
- Update the guidance for verifying the ongoing equivalence of foreign food safety systems.
- Develop and implement guidance to foreign countries for achieving Individual Sanitary Measures (ISMs) in obtaining FSIS equivalence determinations.
- Develop and implement guidance for foreign countries about what might lead to delisting and reasons for the action.
- Revise procedures for documenting deviations from visiting the minimum number of establishments while doing foreign equivalence verifications.
- Revise procedures for postponing or canceling a scheduled ongoing equivalence verification audit or for ceasing a visit.
- Change procedures, for complete verification audits before the first shipment from the country.
The OIG conducted most of its work at the FSIS offices in Washington D.C., but staff tagged along on FSIS verification audits of Northern Ireland and Denmark. The fieldwork for the review was conducted from August 2015 through February 2017.
The OIG also looked at six prior country audits: Australia, Canada, Chile, China, Honduras and Northern Ireland. The review also examined technology available to FSIS to assist with the country audits.
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