POSSIBLE BENEFITS, COSTS, AND UNINTENDED ADVERSE CONSEQUENCES

The committee identified a number of favorable outcomes that might be anticipated as a consequence of the public release of FSIS establishment-specific data. At the most basic level, such release would directly serve the first broad purpose of transparency in supporting the public’s right to know. It would also serve the second broad purpose of transparency in helping to achieve specific public-policy goals. In the latter role of “targeted transparency”, the major effects of expanded data access would include the potential for better decision-making based on improved information and stronger incentives for both the agency and food companies to improve their performance.

Although it has not been definitively documented, one of the expected advantages of providing public access to establishment-specific FSIS data is the improvement of public health. That appears to have been the case for the Environmental Protection Agency’s release of Toxics Release Inventory data and the publication of restaurant-inspection data (see Chapter 3). Releasing establishment-specific FSIS data could potentially motivate individual companies and sectors of the food industry to improve their overall food safety efforts. For example, data release could provide incentives to protect brand reputation in food safety and to protect or enhance customer base and profitability; allow downstream purchasers and consumers or public-interest organizations to identify companies whose performance records were consistently above or below the industry average and potentially create economic pressure to improve food safety; provide better insights into strengths and weaknesses of different processing practices, which could lead to industrywide improvements in food safety practices; enhance performance benchmarking by individual companies, sectors, and the industry as a whole, including efforts by individual companies that are seeking to avoid being identified as “below average”; and improve the consistency of inspector performance.

Even if individual firms do not change their behavior in response to data posting, overall food safety could improve if information about performance leads consumers to favor high-performing establishments and hence causes a shift in the composition of the market. In addition to providing incentives for the private sector, release of establishment-specific data could help to identify needs for improvement in regulatory practices, and this might result in activities that lead to improved public-health outcomes. For example, industry representatives raised concerns about variation in enforcement practices among inspectors and districts. Analysis of enforcement data could help to identify variability in enforcement outcomes (if present) of comparable facilities. It could also help to identify effective practices in regulated facilities that could be more broadly adopted. As in other systems that provide establishment-level enforcement data, a coding system could be developed to protect the identities of individual inspectors and still achieve the above outcomes.

Public release of establishment-specific FSIS data, by themselves or in combination with other privately or publicly available data, could yield valuable insights that go well beyond the regulatory uses for which the data were collected. For example, establishment-specific FSIS microbial testing data might be combined with region-specific climate data in an effort to develop better predictive risk models of pathogen load as a function of environmental conditions. Making establishment-specific data publicly available might provide information that would be useful for training the next generation of researchers, regulators, and industry food-safety



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