I'd hate to type "red flag" into Google News these days. Red flags on mortgage lenders. Red flags on Madoff. Red flags on banks. Red flags in peanut factories.
Better than seeing red flags would be catching folks red-handed. Here is a tale about why an FDA inspector might have a hard time.
The FDA arrives at a plant unannounced. Virtually nobody has a receptionist anymore, so the inspector picks up a phone in the lobby and dials an extension. Eventually, our inspector -- lets say Sherlock -- gets a clerk on the phone. The clerk says just a moment; we'll get somebody out to meet you.
The clerk calls the plant manager, Moriarty. The plant manager says to the clerk, "Hang up, get on the paging system and page me -- and be sure to mention that the FDA is in the lobby."
Sherlock hears over the plant-wide speakers "Mr. Moriarty, the FDA inspector is in the lobby. Mr. Moriarty, the FDA inspector is in the lobby." The clerk then comes out to tell the inspector that the plant manager is somewhere in the plant, but he'll be along in a few minutes.
Moriarty doesn't want to keep Sherlock waiting too long, but he's now got five minutes at least to issue marching orders. Worst case, he can say he was in the bathroom. By the time Moriarty gets to the front door, everybody in the plant knows the FDA is in the building and they are scrambling to get ship-shape.
Now the game is delay -- how long can Moriarty keep the inspector off the plant floor? Moriarty knows that Sherlock has quite a long list of preliminaries to work through -- especially if Sherlock is new to the company and this facility. And Moriarty can also buy substantial time with some polite questions, some small talk, and taking his time to find the paper work and documents Sherlock will ask for.
Midway through preliminaries an office person (never a person dressed to work in the plant) interrupts the meeting. "Mr. Moriarty, there is an urgent call for you." "Please excuse me, Sherlock, but I've got to take this -- we've had, uh, uh, some threats from a former employee and I need to talk to the police."
Mr. Moriarty goes around the corner, and there is the assistant plant manager. "Mr. Moriarty, what are we going to do about the roof leak?" "Call Bob at Bob's Construction and tell him to get his ass over here right now with a crew. I want them on the roof in 30 minutes. Oh, and take that 10,000 pounds of crappy-looking ingredients off the production floor and move them over to the loading docks. Plaster those red 'HOLD' stickers all over them and date them yesterday. If anybody asks, we're holding them for disposal, but the seller wants to come see them first." Later, Moriarty will be able to point to both of these of as evidence of his diligence.
Sherlock asks if Moriarty has a HACCP plan. Moriarty says no. Sherlock contains his urge to let out a huge sigh of relief. The last thing he wants to do is spend four or five hours pouring over paperwork to see if all the i's are dotted and t's are crossed on a HACCP plan.
Finally the preliminaries are over, and it is time to begin the inspection. If Sherlock has been in the plant -- and knows where the red flags were last time --he can head straight for them. But this isn't Sherlock's first rodeo, so maybe his best chance is to head elsewhere, since those red flags are probably gone. If Sherlock hasn't been in the plant, Moriarty has effective control of the tour, and Sherlock will get to the worst areas last -- and slowly.
If Moriarty is half-competent, any major sins are now dealt with. We're not going to be caught red-handed today. Sherlock knows this, so he goes looking for more subtle red flags. Rodent droppings in obscure corners. Hard to access parts of machinery that might not have been cleaned in a decade. Torn up truck dock seals. Duct tape and cardboard covering openings in conveying lines. Cleaners and sanitizers that are out of date or just jumbled in a pile in a corner. There are lots of clues that an experienced inspector such as Sherlock can use to get a sense for what is going on when he's not around, and for the general level of vigilance.
When he finishes, Sherlock has a bad feeling, so he decides write Moriarty up for everything he finds. A couple, three red flags. But not red-handed. And no real basis for pulling product samples or doing environmental swabs, let alone more drastic action. Man, would it be nice to check this outfit really frequently for awhile, do some testing -- find some way to keep them under the microscope, so to speak. I'd also love to know how much turnover they have, and how they train new workers on sanitation, and how they clean up every day. Man, wouldn't it be cool to go undercover like on TV and really see what is going on?
A nice fantasy. But no way do we have the time or budget for this. And I'm still a month behind on routine work from running down that last recall.
OK, story over. To the extent our food is safe, there are three reasons. The first is that some food companies want to do the right thing because it is the right thing. Advantages: cheap. Disadvantages: ineffective. The second is that some food company employees are smart enough to take a long term view and see that the risks of cutting corners in a way that destroys the confidence of customers is suicide. They aren't moral -- just smart. Advantages: cheap. Disadvantages: some food company employees are idiots. The third is inspection. Advantages: Properly-funded, can really help. Disadvantages: Expensive, highly unlikely to be properly funded (in part because success is when nothing happens).
The optimal solution is to find a way to focus inspection on identifying the idiots and watching them close. Easy to say; hard to do. There are always more idiots.