At least one diary had been posted talking about how regulation can not make our food safe. I agree, to some extent. Regulations, without enforcement, are completely worthless. I also accept that some very ethical firms do not need any regulation, because they set the standards that are even better than the regulatory ones.
But then there the ones at the bottom of sanitary standards, the ones that need regulation very much, to the point of being shut. In the middle are the vast majority of the ones that could benefit, and so could the public, with positive regulation.
What is positive regulation? This is a concept that I developed whilst being part of FDA. Simply, it is going into plants and working with the operators to make things better. Of course, there will be violations, and those must be addressed. Sometimes, penalties will have to be assessed if there are blatant violations, ones that everyone running a plant should realize.
But, for the most part, it involves the FDA working with operators to fine tune "little things" that, whilst not being a problem at present, could contribute to a major contamination event. I would posit that no penalty should be assessed in those cases, if the operators work with the agency to make it right.
Case in point: several years ago, a brass smelter swept the flue out for zinc oxide to put in animal food supplements. They did not know that the salvaged copper wire, with polyvinyl chloride insulation, produced dioxin that coprecipitated with the zinc oxide. As it turned out, many thousands of food animals, including swine, beef, and catfish, were contaminated with dioxin. It did enter the human food chain.
With closer cooperation between the agency and industry, this might have been avoided.
Any comments, criticisms, or questions are welcome.
Warmest regards,
Doc