Detailed Information on the
Food Safety and Inspection Service Assessment

FSIS will implement a risk-based inspection system beyond the current pilot program.

Measure: Reduction in the prevalence of foodborne illness from meat, poultry and egg products In 1997 there were 76 million illnesses related to foodborne hazards.

Explanation:Long-term foodborne infection estimates are reliant upon intermittent CDC assessments of the Nation's overall health status and reflect infections associated with all food sources. While the first comprehensive estimate identified 76 million illnesses in 1997, 1999 FoodNet data indicates a 19% decline from the 1997 incidence. More current estimates are not available, but are expected to be developed and published yearly by CDC.

Measure: The prevalence of Salmonella on raw meat and poultry products as illustrated by: Prevalence of Salmonella on broiler chickens (%)

Explanation:

Measure: Percentage of ready-to-eat meat and poultry products testing positive for Listeria monocytogenes (Listeria is a common bacteria that when ingested can cause flu-like symptoms. The bacteria can result in miscarriages and stillbirths.)

Explanation:

Measure: Millions of pounds inspected per FTE. (New measure, added February 2007)

Explanation:FSIS is committed to making its inspection systems as efficient as possible while protecting public health. In future years, this efficiency measure will increase with the implementation of a more robust, risk-based inspection system.

Is the program purpose clear?

Explanation: The mission of Food Safety and Inspection Service is to ensure that the Nation's commercial supply of meat, poultry, and egg products is safe, wholesome, and accurately labeled and packaged.

Evidence: Federal Meat Inspection Act (FMIA) 21 U.S.C., Chapter 12, P.L. 59-242 as amended through P.L. 107-1; Poultry Products Inspection Act (PPIA) 21 U.S.C., Chapter 10, P.L. 85-172; Egg Products Inspection Act (EPIA) 21 U.S.C Chapter 15, Section 1034, P.L. 106-170

Does the program address a specific interest, problem or need?

Explanation: The Centers of Disease Control and Prevention (CDC), DHHS, estimate that foodborne diseases cause approximately 76 million cases of gastrointestinal illnesses, 325,000 hospitalizations, and 5,200 deaths in the U.S. each year. Further the Economic Research Service, USDA, estimates that the costs associated with five major pathogens alone amount to at least $6.9 billion annually. These costs include medical costs, productivity losses from missed work, and an estimate of the value of premature deaths, but exclude travel costs in obtaining medical care, lost leisure time, etc.

Evidence: CDC, "Food-Related Illness and Death in the United States," Paul S. Mead et.al.., Emerging Infectious Diseases, Vol. 5, No. 5, 1999; ERS, Food Safety Efforts Accelerate in the 1990's, Stephen R. Crutchfield, Tanya Roberts, 2000; GAO-02-902, Meat and Poultry-USDA Oversight and Enforcement of Safety Rules Needed to Reduce Risk of Foodborne Illnesses; OIG-24001-3-AT, FSIS: Implementation of the Hazard Analysis and Critical Control Point System.

Is the program designed to have a significant impact in addressing the interest, problem or need?

Explanation: The CDC combined estimated incidence of infections caused by Campylobacter, E. coli O157, Listeria, and Salmonella in 2001 was 21% lower than in 1996. According to CDC, the declines in the incidence of these foodborne infections occurred in the context of several control measures, including implementation by USDA/FSIS of the PR/HACCP systems regulations in meat and poultry slaughter and processing plants. The decline in the rate of Salmonella infections in humans coincided with a decline in the prevalence of Salmonella isolated from FSIS-regulated products to levels well below baseline levels before HACCP was implemented.

Evidence: CDC, Preliminary FoodNet Data on the Incidence of Foodborne Illnesses---Selected Sites, United States, 2001, MMWR, April 19, 2002.

Is the program designed to make a unique contribution in addressing the interest, problem or need (i.e., not needlessly redundant of any other Federal, state, local or private efforts)?

Explanation: Principal Federal regulatory organizations responsible for providing food safety consumer protection are the FSIS and FDA (HHS). FSIS has the sole regulatory responsibility for ensuring that meat, poultry, and egg products are safe, wholesome, and accurately labeled and packaged. The FSIS role is unique but not conducted in a vacuum. Other Federal agencies, such as ARS, APHIS, AMS, CSREES, EPA, ERS, and CDC play a significant role in food safety research, education, prevention, surveillance, standard-setting, and outbreak response activities (see 2.4). FSIS has agreements with 27 States to ensure that these delgated inspection programs are "equal to" Federal inspection conducted in the other 23 States.

Evidence: A Description of The U.S. Food Safety System, interagency paper prepared as the U.S. March 2, 2000 submission to the Organization for Economic Cooperation and Development; FMIA 21 U.S.C., Chapter 12, Section 301; PPIA 21 U.S.C., Chapter 20, Section 5. EPIA 21 U.S.C., Chapter 15, Section 1034; A list of agreements with States is available upon request.

Is the program optimally designed to address the interest, problem or need?

Explanation: Within the constraints of underlying statutory requirements for carcass by carcass visual inspection, FSIS is tied to a certain inspection protocal that makes it impossible to compare the allocation of inspection resources to the level of inspection resources used at FDA. Within the constaints of the traditional model, the PR/HACCP rule began a new era of meat & poultry inspection and there is no evidence that another approach that would be more effective in achieving the reduction in foodborne illnesses. Under HACCP, plants identify and evaluate the food safety hazards that could affect the safety of their products and institute controls necessary to prevent these hazards from occurring or to keep them within acceptable limits. However, HACCP inspection does not apply to the slaughter process. The HACCP-Based Inspection Models Project (HIMP) is an effort to improve online slaughter inspection, and to maximize the reduction and/or elimination of defects that pass through traditional inspection.

Evidence: National Academies of Science Reports dating from 1986; PR/HACCP Rule, 9 CFR Part 304, et. al.; HIMP June 1997, Fed Reg 62 FR 31553, FSIS requested public comments on the design and development, Fed Reg Notice: HACCP-Based Meat and Poultry Inspection Concepts: Diseases and Conditions Identifiable During Post-Mortem Inspection, Notice of availability July 29, 1998; Memorandum of Understanding between FSIS and NJC, May 19, 1999; RTI data presented to the National Advisory Committee on Meat and Poultry Inspection June 2002;

Does the program have a limited number of specific, ambitious long-term performance goals that focus on outcomes and meaningfully reflect the purpose of the program?

Explanation: The current strategic goal for the Agency is to protect the public health by significantly reducing the prevalence of foodborne hazards from meat, poultry, and egg products. Through various GPRA documents, the Agency and USDA have attempted to measure this reduction; first through the use of CDC foodborne illness data and currently through the use of Listeria data on ready-to-eat products and Salmonella data on broiler chickens, market hogs, and ground beef. This latest measure was established in consultation with OMB and is currently incorporated into a performance measure for both the Agency and USDA. The four strategic objectives, and corresponding outcome measures, are based on the risk analysis model; a well recognized scientific approach. They include risk assessment, risk management, risk communication, and the infrastructure to support the model. This framework was constructed in conjunction with food safety partner agencies throughout the government. USDA is currently producing a new Strategic Plan.

Evidence: USDA Strategic Plan 2000-2005: USDA Annual Performance Plan (APP) 2002-2003; USDA Annual Program Performance Report (APPR) 2001; FSIS Strategic Plans for Fiscal Years 1997-2002, 2000-2005 May 2001; FSIS APP for FY 2002 -2003, FSIS APPR for FY 2001, Most FSIS Strategic Plans, APPs and APPRs are available on the FSIS Web site.

Does the program have a limited number of annual performance goals that demonstrate progress toward achieving the long-term goals?

Explanation: FSIS Annual Performance Plans contain four strategic objectives converted to performance goals and outcome measures that have annual targets. As with the Strategic Plan, it is based on a risk analysis model that includes risk assessment, risk management, risk communication, and the infrastructure to support the model. Outcome measures, and corresponding annual targets, demonstrate progress made towards achieving both the annual and long term goals. USDA is producing a new Strategic Plan that will impact the FSIS Strategic Planning process. This evolving planning process will incorporate: current science on the causes of foodborne illnesses, estimated severity and likelihood of harm to human health, policy alternatives to protect public health in view of risk assessments, and information exchange among all stakeholders.

Evidence: FSIS APP 2002-2003; FSIS APP 2001-2002; FSIS APP 2000-2001; FSIS APPRs FY 2001, 2000, 1999; FSIS Strategic Plan 2000-2005, May 2001

Do all partners (grantees, sub-grantees, contractors, etc.) support program planning efforts by committing to the annual and/or long-term goals of the program?

Explanation: There is no concrete evidence to support or rebut the answer to this question. State inspection programs must be equal to those of Federal inspection programs so these States do play a role in reducing the incidence of foodborne illnesses. FSIS currently reviews approximately 22% of State inspection programs each year.

Evidence: FMIA 21 U.S.C., Chapter 12, Section 301; PPIA 21 U.S.C., Chapter 20, Section 5; FSIS had 27 grants with cooperative State meat and poultry inspection programs in 2001. A list is available upon request.

Does the program collaborate and coordinate effectively with related programs that share similar goals and objectives?

Explanation: The framework for the current FSIS Strategic Plan was designed in consultation with related programs. FSIS has over 70 MOUs and Interagency Agreements with food safety partner agencies to cooperate on research, education, prevention, surveillance, and outbreak response. An example of effective food safety partner coordination is the Fight Bac education campaign that involves State, local, Industry, and Federal agency collaboration. Another is the recent APHIS and FSIS risk assessment on Bovine Spongiform Encephalopathy (BSE). The Food Threat Preparedness Network (PrepNet) ensures effective coordination of food security efforts across Federal departments. FSIS coordinates with the Agricultural Research Service (ARS) for food safety research, with APHIS to prevent diseased animals from entering the food system, and with FDA to share information. FSIS contributes to the CDC FoodNet and PulseNet, a national network of public health laboratories.

Evidence: USDA APPR FY 2001 contains information on USDA food safety partners; Source documents for the Fight Bac campaign can be found on the FSIS Website; CDC and FDA data incorporated into FSIS APPs and APPRs; MOU example includes 12-37-379 with FDA for exchange of information regarding establishments and operations that are subject to duel jurisdiction; Interagency Agreement 12-37-2-032 with ARS for research, 12-37-2-058 with CDC for FoodNet surveillance; A listing of Interagency Agreements, MOUs, and Cooperative Agreements will be furnished upon request.

Are independent and quality evaluations of sufficient scope conducted on a regular basis or as needed to fill gaps in performance information to support program improvements and evaluate effectiveness?

Explanation: Independent and quality evaluations have been conducted by GAO, OIG, Logistics Management Institute (LMI), and Research Triangle Institute (RTI). Through the RTI, FSIS is conducting a comprehensive evaluation of the impact of the HACCP rule. This multi-year project, started in FY 1999, is in addition to internal FSIS assessments of HACCP impact and implementation. For information regarding LMI evaluations of financial controls, see Section 3.6.

Evidence: The list of reviews is available upon request. Samples include: RTI Study, Effects on PR/HACCP on Biological Hazards: PreHACCP Study, Dec. 2000; GAO--02-59, Food Safety-Weakness in Meat and Poultry Inspection Pilot Should Be Addressed Before Implementation; OIG-50601-3CH Assessment of APHIS and FSIS Inspection Activities to Prevent the Entry of Foot and Mouth Disease Into the U.S.; OIG-24001-3-AT, FSIS: Implementation of the Hazard Analysis and Critical Control Point System; OIG-24601-CH, FSIS: Laboratory Testing of Meat and Poultry Products.

Is the program budget aligned with the program goals in such a way that the impact of funding, policy, and legislative changes on performance is readily known?

Explanation: The Agency has attempted to use output measures for new initiatives that have illustrated funding, policy, and legislative changes. However, not all have always tied to the budget as some did not require additional resources but were discussed within the Plan without clear performance measures. FSIS can cross walk 2004 budget with the Strategic Plan and performance data will be incorporated into the 2004 budget justification. Currently, FSIS is looking into its planning and budget formulation activity to strengthen performance-based budgeting and reviewing operating accounts to determine what needs to be accomplished to gather and enhance performance data.

Evidence: FSIS APP FYs 2002-2003; FSIS APP FYs 2001-2002; FSIS APPR FY 2001; Prior year FSIS APPs and APPRs.

Has the program taken meaningful steps to address its strategic planning deficiencies?

Explanation: FSIS is updating its Strategic Plan to synchronize with that of USDA; however, integration in the strategic planning process with other Federal food safety partners (FDA, CDC) and external stakeholders is insufficient. FSIS has taken steps to design an outcome measure, for which data is available on an annual basis, that reflects the unique contribution of FSIS inspection of meat, poultry, and egg products to reducing the incidence of foodborne illness (Strategic goal).

Evidence:  

Are all regulations issued by the program/agency necessary to meet the stated goals of the program, and do all regulations clearly indicate how the rules contribute to achievement of the goals?

Explanation: All regulations issued by FSIS are considered necessary to reduce the incidence of foodborne illness and the meet the mission of the Agency. (Need to mention reg reform here -- where are old regs being revised or withdrawn if not consistent with HAACP?)

Evidence: Examples include: PR/HACCP rule 9C.F.R. Part 304, et.al.; HACCP related rules, Advanced Meat Recovery System; Performance Standards for the Production of Processed Meat and Poultry Products.

Does the agency regularly collect timely and credible performance information, including information from key program partners, and use it to manage the program and improve performance?

Explanation: FSIS data sources include the Microbiological and Residues Contamination Information System (MARCIS) and the Pathogen Reduction Enforcement Program (PREP). MARCIS is an automated system that provides information on microbiological, chemical, and pathological analyses of domestic and imported meat, and poultry and their processed products. PREP is an automated system that is used for scheduling and recording Salmonella compliance data. FSIS has, through its RTI and LMI contracts (see sections 2.5 and 3.6), collected credible program and management performance data. FSIS also contributes to ARS research, CDC FoodNet data collection activities, and FDA FoodCode data. These data are used to monitor and improve performance.

Evidence: Cite APP and APPR

Are Federal managers and program partners (grantees, subgrantees, contractors, etc.) held accountable for cost, schedule and performance results?

Explanation: FSIS annually conducts reviews of approximately 22% of State inspection programs funded in part through the Agency. FSIS implemented new SES personnel performance standards pertaining to GPRA accountability that went in to effect July 1, 2002. The process for middle managers will begin as their standards are updated in October of this calendar year.

Evidence: A list of public meetings is available upon request. Some data also contained in the FSIS Strategic Plan, APPs and APPRs.

Are all funds (Federal and partners') obligated in a timely manner and spent for the intended purpose?

Explanation: Funds control reports from the FFIS accounting system are issued monthly to meet OMB and Treasury requirements for reporting information. Monthly status of funds reports, that separately identify major Agency initiatives, are also delivered to the appropriate Agency program managers. FSIS will intensify its efforts to integrate performance measures into the reports produced by its financial management system in FY 2003.

Evidence: FSIS Financial Statements to USDA and Treasury; FSIS Budget Explanatory Notes to Congress.

Does the program have incentives and procedures (e.g., competitive sourcing/cost comparisons, IT improvements) to measure and achieve efficiencies and cost effectiveness in program execution?

Explanation: FSIS does not have tangible incentives or procedures in place to measure cost effectiveness. However, over the last few years, FSIS has undertaken several initiatives to improve resource management efficiencies and cost effectiveness. Some examples include the prior reorganization which removed one level of field management and consolidated policy development activities, the LMI contract discussed in Section 3.6, FAIM, HIMP, and FACTS. The Agency also has recently reviewed its District offices to determine and adjust the number and structure of field offices needed to achieve maximum efficiency. A parallel review was conducted of field administrative support functions to improve the alignment and responsiveness to Agency programs. The new organizational structure implemented internally August 11, 2002, emphasizes accountability in all FSIS activities. Another recent example includes the Office of Program Evaluation, Enforcement and Review (PEER). This office was established to provide internal review of FSIS programs and assess the effectiveness of regulatory activities.

Evidence: Cite the FACTS initiative here?

Does the agency estimate and budget for the full annual costs of operating the program (including all administrative costs and allocated overhead) so that program performance changes are identified with changes in funding levels?

Explanation: FSIS is analyzing ways in which programmatic costs can be associated within the financial management system to each performance measure. FSIS has incorporated into its financial management system a cost allocation module to distribute, as each month is closed in FFIS, overhead costs to direct program activities. Overhead is distributed to each direct budget activity, and within each activity, each division.

Evidence: FSIS Financial Statements to USDA and Treasury; FSIS Budget Explanatory Notes to Congress.

Does the program use strong financial management practices?

Explanation: FSIS contracted with the Logistics Management Institute (LMI) to evaluate financial business processes and make recommendations to enhance them. This relationship has been ongoing for the last three years. FY 2003 is the target year for implementing most major changes. As a result of this activity, FSIS financial management practices have improved significantly. LMI has provided recommendations to the Agency for improvements and FSIS has begun implementation. There remain some deliverables currently pending.

Evidence: The improvements to the FSIS financial management practices are illustrated in Agency responses to the following: USDA Consolidated Financial Statement for FY 2001, OIG-50401-43-FM; Review of FSIS Inspector Staffing Shortages and Anti-Deficiency Act Violations, OIG-24601-1-FM; LMI Report, FSIS's Accredited Laboratory Program Review of Financial Functions, May 2002; LMI Report, Improving Financial Management at the Food Safety and Inspection Service, Oct. 2001; LMI Report, FSIS's Financial Management and Accounting System: Recommended Improvements and Implementation Strategy, Sept, 2000.

Has the program taken meaningful steps to address its management deficiencies?

Explanation: According to OIG, the major management challenge faced by FSIS is addressed in four audits issued in FY 2000 on the FSIS implementation of HACCP, laboratory testing of meat and poultry products, imported meat and poultry inspection process and the district enforcement operations compliance activities. The Agency has taken corrective action on many of the recommendations and plans to complete the remainder within FY 2003. GAO issued an audit on the HIMP program in December 2001. FSIS has completed some activity to address the issues raised, and plans to complete all corrective actions recommended during FY 2003. FSIS has established an internal controls staff unit, to identify and analyze problems, and to oversee implementation of management improvement actions as necessary.

Evidence: GAO audit entitled Food Safety: Weaknesses in Meat and Poultry Inspection Pilot Should Be Addressed Before Implementation; in addition the Agency regularly conducts Internal Control Reviews and Assessments of management practices.

Did the program seek and take into account the views of affected parties including state, local and tribal governments and small businesses, in drafting significant regulations?

Explanation: As part of the HACCP implementation, FSIS began a comprehensive outreach effort to build consensus among large, small, and very small plants, the National Advisory Committee on Microbiological Criteria for Foods, Codex Alimentarius, and the National Advisory Committee on Meat and Poultry Inspection. Since 1995, FSIS has conducted an extensive public outreach effort, with more than 145 meetings with constituencies; held conferences on a variety of topics on proposed or draft regulations (an example being the action plan for control of Listeria monocytogenes) and plans more on topics such as the Listeria Summit, and improving the recall process. In addition, conferences are held with State governments in conjunction with other food safety agencies.

Evidence: A list of public meetings is available upon request. Some data also contained in the FSIS Strategic Plan, APPs and APPRs.

Did the program prepare, where appropriate, a Regulatory Impact Analysis (RIA) that comports with OMB's economic analysis guidelines and have these RIA analyses and supporting science and economic data been subjected to external peer review by qualified specialists?

Explanation: The Agency has prepared regulatory impact analyses (RIA) which incorporated a statement of need or market failure argument. Reasons for rulemaking ranged from a lack of information to consumers to regulatory reform. All RIAs have shown that the rulemaking maximized net benefits, e.g. the Performance Standards for the Production of Processed Meat and Poultry Products, and Advanced Meat Recovery System. In addition, this RIA and others were subjected to peer review by other government agencies like the FDA and ERS, and by State agencies.

Evidence: Examples include the Performance Standards for the Production of Processed Meat and Poultry Products; Advanced Meat Recovery.

Does the program systematically review its current regulations to ensure consistency among all regulations in accomplishing program goals?

Explanation: FSIS has undertaken, but not completed, an effort to ensure that regulations are converted to performance standards to support the new HACCP system. Regulations are also reviewed on a systematic basis such as the 610 Review process for small Business compliance. Regulations are reviewed on an ongoing basis in an attempt to minimize the regulatory burden on industry and ensure consistency with HACCP goals. During HACCP implementation, FSIS actively reviewed all of its regulations to either delete, rewrite, or adjust to ensure that the older regulations were in keeping with the PR/HACCP rule.

Evidence: Examples include the 610 Review: Standards and Labeling Requirement for Mechanically Separated Species and Products in Which It is Used; Performance Standards for Bacon; Food Standards: Guiding Principles and Food Standard Modernization.

In developing new regulations, are incremental societal costs and benefits compared?

Explanation: In many of the FSIS rulemaking endeavors, the Agency conducts a preliminary cost and benefit assessment to determine incremental costs and benefits. For those rulemakings deemed economically significant, a RIA to assess the costs and benefits of alternatives is conducted.

Evidence: Examples include the Food Standards: Guiding Principles and Food Standards Modernization; Performance Standards for the Production of Processed Meat and Poultry Products; Advanced Meat Recovery.

Did the regulatory changes to the program maximize net benefits?

Explanation: FSIS conducts regulatory impact analysis to determine whether proposed changes maximize net benefits. Not all benefits can be quantified; and in some cases qualitative benefits were determined to justify the costs. In some cases FSIS determines that regulatory changes are the most cost effective, given the constraints of time.

Evidence: Examples include: Food Irradiation; Retained water in Raw Meat and Poultry Products; Poultry Chilling Standards; and Nutrition Labeling of Ground or Chopped Meat and Poultry Products and Single-Ingredient Products.

Does the program impose the least burden, to the extent practicable, on regulated entities, taking into account the costs of cumulative final regulations?

Explanation: In all instances, the regulatory impact analysis takes into account the costs of a regulation, especially on small entities, and attempts to impose the least burden on industry. Rulemakings that require industry to make reports to the Agency, in terms of information collection, are kept to a minimum in order to reduce the paperwork requirements on these establishments, in most cases.

Evidence: Examples include: Retained Water in Raw Meat and Poultry Products; Poultry Chilling Performance Standards; Food Irradiation.

Has the program demonstrated adequate progress in achieving its long-term outcome goal(s)?

Explanation: FSIS has achieved this but with difficulty. The problem has been with a long term goal and measurement selection and 1) availability/applicability of data to internal program activity and the 2) FSIS budget correlation with the Strategic Goal has been a troublesome relationship over the years. It remains so today. Current thinking is to design a new strategic outcome measure that is based on those risk analysis activities that specifically focus on industry compliance with food safety standards that reduce preventable illnesses and outbreaks. While this would not be a direct indication of reduction of foodborne illness, it would allow FSIS to illustrate its activities that impact the long-term outcome. The first FSIS Strategic Goal was designed when the Agency was being its HACCP implementation strategy to arrive at an approximate 25% reduction in foodborne illness.

Evidence: CDC, Preliminary FoodNet Data on the Incidence of Foodborne Illnesses, 2002; RTI reports Changes in Levels of Three Biological Hazards in Ready-to-Eat, Processed Meat and Poultry, and Raw Ground Beef Products Since the 1996 PR/HACCP Rule, Aug. 02-draft; Changes in Identification and Control of Physical Hazards Since the 1996 PR/HACCP Rule, Aug. 2002 draft; and FSIS internal reports.

Does the program (including program partners) achieve its annual performance goals?

Explanation: In its FY 2001 APPR, FSIS illustrated that it had met or exceeded most of its outcome measures for its performance goals.

Evidence: FSIS FY 2001 APPR

Does the program demonstrate improved efficiencies and cost effectiveness in achieving program goals each year?

Explanation: Even though FSIS meets many of their annual performance goals, there is not data available to indicate that FSIS is improving efficiency and cost effectiveness each year. FSIS has over the years streamlined its administrative structure and conducted pilot programs designed to deliver inspection services more efficiently. However, these efforts are limited to re-designed inspection systems that must meet the legislative mandate to inspect meat and poultry on a carcass by carcass basis.

Evidence: HIMP pilot discussed in Section 1.5.

Does the performance of this program compare favorably to other programs with similar purpose and goals?

Explanation: While there are other Federal food safety regulatory agencies, differences in statutory requirements placed on each agency make comparisons difficult. This is especially true when comparing frequency of inspections.

Evidence: FMIA 21, U.S.C., Chapter 12; PPIA 21 U.S.C., Chapter 10; EPIA 21 U.S.C., Chapter 15, Section 1034.

Do independent and quality evaluations of this program indicate that the program is effective and achieving results?

Explanation: Data does indicate that FSIS is achieving results; however, limitations of the data make it impossible to validate exactly the food safety measures that are responsible (for example; inspections versus in-home measures). FSIS has a multi-year contract with RTI. Eight studies are completed or targeted for completion this fall. One study is to determine the impact of the PR/HACCP on foodborne illness and a second one on hazard levels in meat and poultry is being conducted. Data will be used to determine which pathogens should be targeted to further reduce foodborne illness levels.

Evidence: CDC, Preliminary FoodNet Data on the Incidence of Foodborne Illnesses, MMWR, April 19, 2002; RTI Reports Effects of PR/HACCP on Biological Hazards: Pre-HACCP Study, Dec, 2000; Changes in Consumer Knowledge, Behavior, and Confidence Since the 1996 PR/HACCP Final Rule, Dec. 2001

Were programmatic goals (and benefits) achieved at the least incremental societal cost and did the program maximize net benefits?

Explanation: Total FSIS FY 2002 costs amount to $2.98 per capita. This compares favorably with other health related preventative actions such as an annual flu shot. As cited in Section 1.2, ERS estimates that the costs associated with five major pathogens alone amount to at least $6.9 billion annually or $24.14 per capita. When considering the fact that foodborne illnesses can cause death and seriously disrupt a family, the cost of $2.98 per capita seem small in comparison to the maximum benefit of reducing the incidence of foodborne illnesses by 21%. While these costs seem small, further changes to modernize the inspection processes could result in lower overall costs with the same or improved food safety benefits.

Evidence: U.S. Census Bureau, monthly national population estimates for resident population plus Armed Forces overseas for the month of October, 2002; FSIS budget for FY 2002; ERS, Food Safety Efforts Accelerate in the 1990's.