Let the fox guard the hen house?  What could possibly go wrong?  This time, somebody who's just gone through the revolving door is suggesting we privatize food safety inspections.

WASHINGTON - The Food and Drug Administration proposed sweeping new rules on Friday that would require food importers like Walmart and Cargill to make sure that their foreign growers and processors were following American food safety standards to prevent contamination in an increasingly globalized food supply.
The rules, if made final, would shift the responsibility for ensuring that food is safe from the F.D.A. to companies. American companies would have to prove that their foreign suppliers had controls in place through actions like auditing the foreign facilities, testing food, and reviewing records.  American importers would have to keep their own records on foreign suppliers. They would be allowed to hire outside auditors to make on-site inspections. [snip]
"If you look at the cost of doing it all by the feds, what you end up with is inadequate dollars," said Dr. David Acheson, a former F.D.A. official who is currently with Leavitt Partners, a food safety and health care consulting firm in Washington. The current system, he said, "doesn't work anymore. So let's leverage the private sector.
NOTE: These 3 paragraphs came from an online version I saw yesterday, that seems to have been taken down from the Times web site.  The link now leads to a very similar story, probably a later version that has been edited.  I'm confident I didn't hallucinate up those three paragraphs.

Well, what could possibly go wrong?  The fox is an expert on the hen house; why not let him guard it?  It's not as if letting the issuers of, say, derivative based securities, be the ones who hire the companies to rate those securities helped cause that economic meltdown in 2008.

I happen to have been through an FDA audit -- not for food, but as medical director at a company that does drug trials.  It was a royal pain in the ass, but one thing I can't fault the inspector for is lack of suspicion.  It seems the same folks do inspections on food processors and drug testers.  This fellow seemed convinced there was hanky-panky when he walked in the door.  Finally, after two weeks, he relented after I pointed out,

"We don't have a dog in this fight.  We'll get paid the same amount from the sponsor of the study (the pharmaceutical company) whether the new medicine gets approved or not.  If anything, I want to be sure the study is as accurate as possible so I'll be able to trust the new medicine if it is approved and I want to use it on my regular office patients.  
"We're not in a position similar to the companies that make those 3-, 5, and 10-pound tubes of hamburger meat.  That stuff has a short shelf life, so they have to start the tests for bacterial contamination on each batch but then ship the stuff before the test results come back.  Three days later, if the tests show contamination, they have to recall the bad lots, just before they hit the supermarket shelves.  That's expensive, -- easily five or six figures -- so the packing companies have a big incentive to suppress the test results.  We're not in that position."
It bears pointing out that there can be a tremendous temptation to suppress those test results.  In this example, there's a good chance that contaminated hamburger meat wouldn't make many people sick.  If it happens to just a few folks, perhaps because the contamination is slight,  it's very unlikely that a pattern that would lead back to a bad batch of meat would be noticed.  And the tests should be sensitive, set to err on the side of safety.  You need vigilant (if not paranoid) inspectors to fight the temptation to tread on that margin of safety.  

(My hamburger meat analogy doesn't exactly apply to the FDA.  The US Department of Agriculture inspects meat.  A recent example from the USDA web site is here:


But hey, it's an analogy anyway.  The temptation to tread on the margin of safety and let things slide can crop up anywhere the wrong test result hits the pocketbook of the same party that's in charge of the test.)

And what of the concern that we can't go inspecting foreign food processing plants?  This story


suggests that a label sporting, "Inspected by the U.S. Food and Drug Administration" could be a big selling point, at least for powdered infant formula in China.  Chinese consumers are paying a huge premium for baby milk powder shipped or smuggled in from the West, because they trust our food inspectors.  Let them import food inspectors in stead.  

Granted, this policy only applies to the 15% of our food that we import, and it may be an improvement over the scanty inspection we have for imported food right now.  But without the FDA at least double-checking the private inspectors enough to keep them on their toes, it's still a loophole looking for a wall.  And once companies like Leavitt Partners get their foot in the door on foreign food inspection, they'll try to muscle in on what the FDA has been doing -- and doing pretty well -- domestically, too.

Today the New York Times ran a revised version of this story.
I think they played down the 'Fox applying for the job of guarding the hen house' aspect this time.  Was that a courtesy to the fox, who put them onto the story in the first place?

6:52 PM PT: Fixed the links -- I think.

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