Does Being ‘Small’ Mean Less Food Safety Risk?

Being a small business person myself, I am all for helping my peers who are working hard to make our businesses successful.  The order that comes with rules and regulations intended for Wall Street can be onerous and difficult to manage for those found mostly on the local main streets.  However, is it correct for FDA to require less food safety controls for smaller food manufacturers than for the larger ones?  I can’t agree that such a principle for regulation is in anyone’s best interests.

First, food doesn’t care much if it comes from a smaller or larger manufacturer. The thresholds for food safety are one and the same.  The rules for use of safe ingredients; equipment sanitation; personnel hygiene; and proper food cooking, storage and distribution practices are the same for small and large operators.  The consequences of consuming unsafe food are marginally different coming from small or large manufacturers, and only because fewer people may be adversely affected if the distribution system is limited, as is likely the case for a smaller operation.  But if you are the one affected and sick with salmonellosis, the impact to you is just as bad.  It hurts to be sick.

FDA should be cognizant that regulations can be developed that are cumbersome, difficult and even unrealistic for smaller operators to comply – but the rules should not be made lax just because of an operator’s size.  The discipline to deliver safe food preparation and handling is necessary for protecting the public health.  Companies who go into the marketplace to sell food need to know that food is perishable and unsafe food makes people sick – and is a liability to their business.  If they don’t want to care about food safety, they should sell candles—not cream pies.

Catherine Adams Hutt
RdR Solutions Consulting
cadams@rdrsol.com

6 Responses

  1. Hum….I wonder if the small processors seeking exemption from these food safety requirements would gamble their families’ well-being and consume food from small independent restaurants, if those establishments were exempt from the U.S. Food Code and environmental health inspections?

  2. While I agree in principle, Catherine, somewhere a distinction must made between commercial operations and those who make and sell food for charitable purposes. Unless the Bill specifically excludes your local school cake stall (and I don’t know if it does), there is a danger of rules being set for such activities which could be the end of all such fund-raising activities. Maybe the business size minimum suggested was designed to avoid such an outcome. Maybe it is simply too high at $500,000?

  3. I agree with Catherine. Small businesses are more often the problem, not the larger ones. When the juice HACCP regulations were finalized, the businesses who were exempt from the regulations were the real problem. FDA came down with a sledge hammer on the entire juice industry because of a problem with small businesses. In the case of juice the problem could have been solved by one simple regulation, mandatory pasteurization or equivalent. While I am not against all of the parts of the new law, it will provide the way for mandatory HACCP or more for the food industry that is manufacturing the safer food.

  4. When you go to the grocery store and buy a package of ground beef , that package has a mixture of muscle from 200-2000 cows. If one of those cows was sick… When you buy a package of grocery store spinach, 100 different temporary workers may have touched the produce in that package. If one of them was sick… In addition, the grocery store meat and the spinach were packed in a modified atmosphere package. This prolongs the apparent shelf life of the product, but reduces signs and smells of spoilage that would have alerted you that the product was not safe 20 years ago. I prefer to buy from local farmers that I have a relationship with. I see and smell where the food comes from.

    It is essentially “The Law of Requisite Variety”. The law stipulates that the individual with the highest amount of flexibility of behavior will have the most influence on the system. That basically means that the more choices you have, the more freedom you will feel, and the better quality of life you can have. With respect to food, the person with the most options in sourcing their food will have the ability to choose their best sources of nutrition. It is important to maintain a variety of suppliers and options for the safety of the food system. Making small businesses exempt from some of the regulation is an effort to keep options available to consumers. I would like to see some government agency or separate not-for-profit organizations develop safety classes catered toward this market. Webinars and local class to help small companies develop respectable food safety plans would help us all.

  5. I agree with Catherine when she says “size shouldn’t matter”. The problem comes with competition, and laws usually drive the small out of business. They just don’t have the funds to compete, which restricts fair competition and sets prices for the consumers to run generally higher. Maybe the answer is to “help” bring the small processors up to whatever law sets as mandatory minimum standards by grants or low intrest loan programs. This would even the playing field and promote healthy competition, which in turn would drive down pricing to consumers. Food Safety should never be compromised no matter how large or small a food manufacturer is.

  6. I agree that all establishments involved form production to delivery of the food to the consumer should be following same food safety management practices. The arguement that foodborne illness outbreaks are confined to small areas (in the State OR within 275 miles radius) in case of ‘local foods’ is not necessarily true because in densely populated areas the numbers are upwards of 100 million.

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