Risk Based Inspection (RBI) is the law of the land for milk and dairy, fruits (like cantaloupe) and vegetables (think Romaine), peanut butter and most seafood.
The Food Safety Modernization Act (FSMA), signed into law by the President Barak Obama on Jan. 4, 2011, mandates that the Food & Drug Administration institute RBI for the food products that fall under their jurisdiction.
This Act came into being just a few years after another new law was passed denying U.S. Department of Agriculture/Food Safety & Inspection Service (FSIS) the ability to change how it inspected meat and poultry further processing plants to an RBI system.
The only difference that I can see in whether or not Congress allowed or even mandated RBI is the FSIS bargaining unit. At 6,500 members strong, the worry was that RBI might eliminate some jobs. Congresswoman Rosa DeLauro, D-Conn., shared that concern.
At FSIS, there were some of us who felt that RBI made perfect sense.
All plants that were further processing meat and poultry products got a daily visit from an FSIS inspector, who might have anywhere from one to five plants on his/her daily circuit.
Most of the time the visit consisted of a brief walk-thru of the plant, then a couple of hours in the small office space dedicated to FSIS to review paper work.
I had suggested that in the 21st century, maybe the paperwork review could be done on-line, saving drive time and increasing inspection time. That idea floated like a lead balloon.
But the idea of the inspectors spending more time in plants with a poor food safety record or in plants making higher risk foods, and less time in plants where food safety was number one and making relatively safer foods, like jerky and smoked hams versus ground beef and ground turkey, did gain some traction.
FSIS started having regular meetings that included industry associations, consumer groups, FSIS inspectors and DVMs, food scientists and industry itself.
Yes, we filled many a conference room for a couple of years.
At first, we had some naysayers.
We conducted three separate surveys just to produce a list of inspected products ranging from safest to riskiest, almost always getting the same results. I considered this demand to convene yet another group just a delaying tactic by some.
At one meeting I actually got yelled at, with the speaker saying, “Dr. Raymond, why are you in such a hurry to get this done?”
Could it be that I had four short years to try and create a change that just might save lives?
At another meeting, when industry was dragging its heels, seeming to try and protect the poorer performing plants (yes, despite daily inspection, there are some that fall into this category) Rosemary Mucklow, who flew in on the red eye flight from San Francisco for every meeting representing the National Meat Assn., said:
“If you want to cut down on drunk drivers, you do not position the State Patrol outside of churches on Sunday mornings; you put them outside of bars on Saturday nights. That is what Dr. Raymond is proposing to do with meat and poultry inspection.”
We moved forward.
We developed two grids, one for plant food safety performance record; the other for the relative safety of each product. Combined, the two grids would determine the relative amount of time spent on inspection, plant by plant.
Total inspection hours would not change, just the time in each plant, some getting less inspection time and others getting more.
After two years we were very close.
After two years Congresswoman DeLauro attached an amendment onto a bill that had to pass that denied the FSIS to spend one more dime of taxpayers’ dollars to develop RBI. That meant we could not even draft an entry for the Federal Register, much less rent a room for another, final meeting.
Then a few years later she and the majority of Congress voted for mandatory RBI for FDA in the FSMA.