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Summary The Food Safety and Inspection Service (FSIS) is the regulatory agency in the US Department of Agriculture that is responsible for ensuring that meat, poultry, and processed egg products produced domestically or imported into the United States are safe, wholesome, and properly labeled. The agency’s mission is carried out by issuing and enforcing food-safety regulations; conducting facility and product inspections, including sampling and testing; responding to foodborne-disease outbreaks; and conducting communication, education, and food-defense activities. FSIS collects a voluminous amount of data in support of its regulatory functions, but the two major types of FSIS data that are currently being considered for public release are sampling and testing data (derived from standard laboratory tests) and inspection and enforcement data (derived from text written by inspectors). Some of those data are already released to the public in aggregated form but not in disaggregated, establishment-specific form. In recent years, the Obama administration has implemented measures to facilitate openness in government, including the requirement that federal agencies publish information on line and provide public access to information in a timely manner; in a form that can be easily retrieved, downloaded, indexed, and searched with tools that are available on the Internet; and without the need for Freedom of Information Act (FOIA) requests. In response to the directive to post high-quality data, FSIS asked the National Research Council to conduct a study to examine the potential food-safety benefits and other consequences of making establishment-specific data publicly available on the Internet (see Box S-1 for the statement of task). BOX S-1 Statement of Task A study committee will examine the potential food-safety benefits and other consequences of making establishment-specific data sets publicly available on the Internet. For each type of establishment-specific data set provided to the committee, the study will: 1. Identify the likely positive and negative impacts or trade-offs of making the data available to the general public, including how factors such as level of aggregation, timing of release, level of completeness, and characterization of the data or context in which the data are presented might affect their utility in improving food safety. 2. Examine potential ways that food-safety benefits and other effects of publicly posting the data might be measured. The committee will prepare a brief report of its findings. 1
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As part of the information-gathering phase of the study, the Committee on a Study of Food Safety and Other Consequences of Publishing Establishment-Specific Data met with representatives of FSIS; a representative of the US Environmental Protection Agency Toxics Release Program, which has experience in public posting of establishment-specific data; and members of the meat and poultry industries. Although there is some evidence on the effects of release of some types of FSIS data (for example, recalls), the committee’s approach to assessing the likely advantages and disadvantages of routine posting of establishment-specific FSIS data was to review evidence of effects based on the experience of other government agencies in releasing such data. The committee also identified general data-release issues that need to be considered and, in light of the unique nature of FSIS data, deliberated on the value of giving the public access to establishment-specific data, with a focus on effects on food safety and public health. The committee’s major findings and conclusions are as follows: Public release of regulatory data is motivated by two broad purposes. The first addresses the public’s right to know about the actions of government. The second, “targeted transparency”, seeks to use information disclosure as a means of achieving specific public-policy objectives. The committee concluded that both those purposes are relevant to the desire of FSIS to release establishment-specific data and that an effective disclosure policy will 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. The committee identified several examples in which federal, state, or local agencies release detailed data that are directly linked to the performance of individual facilities or firms or to their products. In many cases, those data originate in regulatory (compliance and enforcement) activities. Three relevant examples are efforts supported by the US Department of Labor (for example, in the Mine Safety and Health Administration), by the US Environmental Protection Agency (for example, in Enforcement and Compliance History Online [ECHO]), and by several state and local public-health departments (for example, through restaurant hygiene and inspection grading). The committee concluded that FSIS would benefit from consultation with those agencies and could build on their effective practices when designing a public-data release program. There is a substantial body of literature on the effects of disclosing establishment-specific regulatory information similar to that collected by FSIS. The literature suggests that release of these sorts of data can have important benefits. Through a review of the literature on the experience of other public agencies, the committee identified a number of potential benefits of public release of establishment-specific FSIS data, including providing incentives to protect brand reputation in food safety or to protect or enhance customer base and profitability; allowing downstream users to identify companies whose performance records are below and above the industry average and potentially to create economic pressure to improve food safety; providing better insights into strengths and weaknesses of different processing practices, which could lead to industrywide improvements in food-safety practices; enhancing performance benchmarking; and improving the consistency of inspector performance. The committee concluded that 2
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public release of FSIS establishment-specific data, by themselves or in combination with other privately or publicly available data, could yield valuable insights that go beyond the regulatory uses for which the data were collected. The committee concluded that the available evidence of adverse effects of public release of establishment-specific data by other government agencies is insufficient to predict specific problems that would be inherent in the release of establishment- specific data by FSIS. In the absence of information specific to FSIS, the committee identified a number of costs or unintended consequences that public release of establishment-specific data might have, including the financial commitment associated with designing and maintaining a useful data-disclosure system; the drawing of inappropriate conclusions as a result of misinterpretation of the data, particularly if appropriate context is not provided to users; adverse effects on international trade; revelation of proprietary or confidential information from the data; and adverse effects on inspector performance. Those unintended consequences might adversely affect some stakeholder groups, but other groups might not consider them adverse. For example, although the literature suggests that disclosure of information about the performance of a specific facility has the potential to affect the facility’s profitability, it is precisely this possibility that creates an incentive for improved performance, which would constitute a benefit from the perspective of the public. On the basis of its review of information and its deliberations, the committee concluded that there are strong arguments supporting public release 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. The committee concluded that to maximize its effectiveness and minimize its potential adverse unintended consequences, data disclosure needs to be guided by a carefully designed information-disclosure strategy. The committee also concluded that effective disclosure systems are designed to allow continuous improvement as users gain a better understanding of how the data might be used and as the agency responds to stakeholder input. The disclosure strategy would consider the utility of the data to be released, how to release them (for example, their presentation), and how to ensure that the data are continuously updated and improved. The committee identified some key features of an effective information-disclosure plan, including ensuring the integrity of the data (requiring the development of protocols to ensure that the data are accurate, timely, and likely to be useful before posting); providing precise and appropriate definitions of what is being quantified and adequate documentation of context (to mitigate the potential for misinterpretation of data); providing support for the analysis of the data by users (at a minimum providing the data in machine-readable form to facilitate third-party analysis); and providing precautions to prevent the linking of portions of the data in ways that would allow users to deduce confidential information about particular establishments. For all data types, it is important to seek periodic input from stakeholders (industrial, academic, and consumer) to understand their needs and 3
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concerns. Focus groups targeted to key stakeholders may be an effective means of accomplishing that. As part of its charge, the committee examined the issues specific to the public release of two types of FSIS establishment-specific data: sampling and testing data (derived from standard laboratory tests) and inspection and enforcement data (derived from text written by inspectors). In their deliberations, committee members expressed different views about the implications of releasing inspection and enforcement data, which are subjective. A minority noted that minimizing the potential adverse consequences of releasing this type of establishment-specific data would be especially challenging, citing concerns about inspector variability, the potential for misinterpretation of the data, and confidentiality issues. The majority, however, believed strongly that public access to this type of data could help to identify variability in inspector performance and enforcement outcomes and ultimately facilitate more uniform inspection. In keeping with the purpose of attaining targeted transparency, public release of establishment-specific data is expected to result in improvement in food-safety efforts on the part of industry and government and ultimately have beneficial public-health outcomes. Although it is not possible to make a direct causal link between public data access and specific food-safety improvements, the committee concluded that measures of 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. For example, public release of establishment-specific data could result in increased compliance with regulatory requirements, and FSIS could measure this. There are also ways of measuring the extent to which released data are used, for example, number of Web downloads, peer-reviewed reports generated, and policy changes. 4