The Potential Consequences of Public Release of Food Safety and Inspection Service...

8/3/2019 The Potential Consequences of Public Release of Food Safety and Inspection Service Establishment-Specific Data

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The Potential Consequences of Public

Release of Food Safety and InspectionService Establishment-Specific Data


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COMMITTEE ON A STUDY OF FOOD SAFETY AND OTHER

CONSEQUENCES OF PUBLISHING ESTABLISHMENT-SPECIFIC

DATA

LEE-ANN JAYKUS, Chair, North Carolina State University, Raleigh, North Carolina

JULIE A. CASWELL, University of Massachusetts Amherst

JAMES S. DICKSON, Iowa State University, Ames

JOHN R. DUNN, Tennessee Department of Health, Nashville

STEPHEN E. FIENBERG, NAS, Carnegie Mellon University, Pittsburgh, Pennsylvania

WILLIAM K. HALLMAN, Rutgers, the State University of New Jersey, New Brunswick

GINGER ZHE JIN, University of Maryland, College Park

GALE PRINCE, Sage Food Safety Consultants, LLC, Cincinnati, Ohio

DONALD W. SCHAFFNER, Rutgers, the State University of New Jersey, New Brunswick

KATHLEEN SEGERSON, University of Connecticut, Storrs CHRISTOPHER A. WALDROP, Consumer Federation of America, Washington, DC

DAVID WEIL, Boston University, Massachusetts


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Statement of TaskA study committee will examine the potential foodfood--safety benefits and othersafety benefits and other

consequencesconsequences of making establishment-specific data sets publ icly available

on the Internet. For each type of establishment-specif ic data set provided to

the committee, the study will:

Identi fy the likely positive and negative impacts or tradeposit ive and negative impacts or trade--offsoffs of making

the data available to the general publicgeneral public, including how factors such aslevel of aggregation, timing of release, level of completeness, and

characterization of the data or context in which the data are presented

might affect theirutility in improving food safetyutility in improving food safety.

Examine potential ways that foodthat food--safety benefits and other effects ofsafety benefits and other effects of

publicly posting the data might be measuredpublicly posting the data might be measured.

The committee will prepare a brief report of its f indings.


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Study Rationale

Government policy on openness and transparency

(Memorandum on Transparency and Open Government,2009)

Requirement to post high-quality data (OMB Memorandum

for Heads of Departments and Agencies, 2009) Requirement to develop plan to make regulatorycompliance data publicly available (Memorandum on

Regulatory Compliance, 2011)

Cost of complying to FOIA requests National Advisory Committee on Meat and PoultryInspection recommendation to obtain guidance from NAS


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Study Approach

Focused on Sampling and Testing data and Inspection

and Enforcement data Reviewed evidence of effects of posting establishment-specific data based on experiences of other agencies Drew conclusions about the potential consequences ofrelease of FSIS establishment-specific data Addressed more specific issues regarding release ofSampling and Testing data and Inspection and

Enforcement data


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There are 2 broad purposes for public

release of regulatory data:The publics right to know-- public access to

information about the activities of governmentis basic to democratic governance

Targeted transparency-- disclosure may

serve as a means of achieving specific publicpolicy objectives


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Conclusion

The committee concluded that both those purposes

( right to know and targeted transparency ) arerelevant to the desire of FSIS to release establishment-

specific data and that an effective disclosure policy wil l

contribute to increased transparency to stakeholders.In addition, releasing establishment-specific data

might also favorably affect public health in ways

whose assessment could be contingent on the

development of measures specifically designed to

evaluate the effects.


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There are several examples in which federal, state,or local agencies release detailed data that aredirectly linked to the performance of individualfacilities or firms or to their products. In many

cases, those data originate from regulatory

activities. Three relevant examples were reviewed: The US DOL (Mine Safety and Health Administration) The US-EPA (Enforcement and Compliance HistoryOnline or ECHO)

Several state/local public-health departments (restaurant

hygiene and inspection grading).


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Conclusion

The committee concluded that FSIS wouldbenefit from consultation with those agenciesand could build on their effective practices

when designing a public-data release program.


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Literature suggests that release of establishment-specific data can have important benefits, such as:

Allowing consumers to make more informed choices

Motivating firms to improve performance, at least along thedisclosed dimensions, which may lead to:

Incentives to protect brand reputation, and/or enhance customer base

and profitability Economic pressure to improve food safety

Enhanced performance benchmarking

Providing better insights into strengths and weaknesses ofdifferent processing practices which could lead to industry-wideimprovements in food-safety practices;

Improving the consistency of inspector performance

Generating research opportunities


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Conclusion

The committee concluded that publicrelease of establishment-specific FSISdata, by themselves or in combination

with other privately or publicly available

data, could yield valuable insights that go

beyond the regulatory uses for which thedata were collected.


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The committee concluded that the availableevidence of adverse effects of public release ofestablishment-specific data by othergovernment agencies is insufficient to predict

specific problems that would be inherent in therelease of establishment-specific data by FSIS.

Conclusion


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Potential costs or unintended consequences that might beassociated with public release of establishment-specific datawere identified:

The potential to draw inappropriate conclusions because of datamisinterpretation, especially if appropriate context is not provided;

Potential to encourage firms to improve in the reported areas, at the

expense of unreported outcomes;

Additional financial commitment associated with designing and

maintaining a useful data disclosure system;

Potential adverse effects on

Inspector performance

Brand reputation

International trade; and

The unintended release of proprietary or confidential information


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Unintended consequences might adversely

affect some stakeholders, but other groupsmight not consider these consequences as

adverse.


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Conclusion

On the basis of its review of information and itsdeliberations, the committee concluded thatthere are strong arguments supporting publicrelease of establishment-specific FSIS data,

especially data that are subject to release under

FOIA, unless there is compelling evidence that it

is not in the public interest to release them.


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Conclusion

The committee concluded that to maximize itseffectiveness and minimize its potential for adverseunintended consequences, data disclosure needs to be

guided by a carefully designed information-disclosurestrategy.

The committee also concluded that effective disclosure

systems are designed to allow continuousimprovement as users gain a better understanding of

how the data might be used and as the agency

responds to stakeholder input.


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An effective information disclosure strategy would consider:

Data uses and users;

Data integrity (accuracy, timeliness, utility);

Data presentation, including facilitation of third-party analysis;

The need to provide precise and appropriate definitions of each data

type and adequate documentation of context (to mitigate the potential

for misinterpretation of data);

The need to provide precautions to prevent the linking of portions of

the data in ways that would allow users to deduce confidential

information about particular establishments.

How to ensure that the data are continuously updated and improved.

A plan for periodic stakeholder input to understand their needs and

concerns.


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The committee believed that FSIS establishment-specific Sampling

and Testing data were amenable to public release as long a

disclosure plan is established and followed.

Because of their subjective nature, committee members expressed

different views about the implications of releasing establishment-

specific Inspection and Enforcement data.

A minority noted that minimizing the potential adverse

consequences of releasing this type of data would be challenging,

citing concerns about inspector variability, the potential for

misinterpretation of the data, and confidentiality issues.

The majority believed strongly that public access to this type of

data could be beneficial in identifying inspector variability and

ultimately facilitating more uniform performance.


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Conclusion

The committee believed that public release of establishment-

specif ic FSIS data would be expected to result in improvement

in food safety efforts on the part of industry and government,ultimately having beneficial public-health outcomes.

In the absence of a means by which to make a direct causal link

between public data access and specific food safetyimprovements, the committee concluded that other outcomes of

public release of establishment-specific data are available and

that documenting those outcomes could provide insights into

the relationship between data release and food safety, e.g.

Intermediate metrics (e.g., data trends, incidence of posit ive pathogen

testing results)

Metrics of data use (e.g., # Web downloads, # peer-reviewed reportsgenerated from the data, documented changes to industry practices)

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