Choice and Efficiency in Food Safety Policy.

• Author: Brown, Douglas M.

This is an interesting book which analyzes conceptual and policy-oriented issues in food safety regulation. The author's maintained hypothesis is that most food safety regulations in the U.S. are inefficient, i.e., existing regulations could be altered such that we could have a safer food supply at a lower cost. The general recommendations for bringing about a more efficient regulatory food system include (1) having an independent cost-benefit analysis done of each regulation, (2) having a single agency in charge of all food safety regulations, and (3) replacing all process design or command and control standards with performance standards. The book is divided into five chapters.

Chapter 1 is an introduction which familiarizes the reader with the intuitive concept of choice and efficiency. The author demonstrates that since the marginal cost of having the food supply completely safe is almost infinite, a perfectly safe food supply is not a rational economic goal. Each chapter is summarized, and the author's conclusions and recommendations for policy are presented.

Chapter 2 includes a succinct presentation of the legislative history of food safety regulation. The author digresses at times into the economics of specific policy issues associated with the specific legislation, which keeps the reader interests on a high plane. Federal food safety regulation is administered by the Food and Drug Administration (food safety), the U.S. Department of Commerce (fish), the U.S. Department of Agriculture (plants and animals), the Environmental Protection Agency (pesticides), and the U.S. Treasury (alcoholic beverages).

Two issues which receive special attention are the Delaney Clause in pesticide regulations, and the new method of meat inspection. The Delaney Clause said we cannot use pesticides which have a positive probability of causing cancer in humans. The author correctly notes that if this probability is very small, and the marginal gain of using the pesticide is large, then we could have an inefficient regulation. In July of 1996, Congress repealed the Delaney Clause. But in its place they substituted one cancer case per million persons as the cut off for pesticide use. So Congress merely went from 1 case per 260 million persons (probability of .3 x [10.sup.-9]) to 260 cases per 260 million persons, which still gives a low probability (.1 x [10.sup.-6]) and fails to consider the marginal gains of using pesticides.

Until now, the U.S. Department...