Friday, December 7, 2007

Managing Risks - A Page from the Australian Playbook

When my husband and I were running our business and trying to ship products to Australia, we had to deal with that country’s tough meat and dairy product import regulations. Australia’s requirements seemed a bit paranoid to us at the time, but their strict import provisions stood the country in good stead. Australia has never experienced a case of mad cow disease.

Australia developed a risk-based approach to food import control that the FDA would do well to examine and learn from. Imported foods fall into one of three categories.

“Risk categorized foods” are those thought to present the greatest risk for food-borne disease. These foods are subjected to the most intensive scrutiny by Food Standards Australia. The first five shipments of each food on the high risk list from each foreign producer are inspected. After five consecutive shipments of a given food have passed muster, one in four shipments of that food from that producer are held for inspection. After 20 successful inspections, the frequency of inspection drops to one in 20 shipments. In all cases, shipments selected for inspection are held until results are known. Any unsatisfactory result causes the risk clock to reset and, of course, the unsatisfactory shipment is refused entry.

“Active surveillance foods” represent the next lower level of perceived risk. Ten percent of shipments of these foods from each and every supplying country are sampled for lab analysis. Because of the lower perceived risk, shipments of these foods are released after sampling.

“Random surveillance” covers all remaining foods not included in one of the two higher risk categories. Five percent of these shipments are sampled randomly for lab analysis.

Food Safety Australia reviews the results of these inspections periodically and, if appropriate, moves foods to a higher or lower risk category.

No system can ensure 100% safety, but basing a screening program on scientific risk assessment, and adjusting that assessment as more information become available seems a logical way to go.

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