In the past. industry has applied HACCP to control hazards where a zero-risk standard rs
appropriate (e.g., broken glass in canned food) The private sector has evaluated the expected
benefits from avoiding product liability as very high relative to the costs of HACCP For microbial
pathogens in raw unbranded products, a zero-risk standard may or may not be appropriate
Regulators and consumer advocates have argued that marginal benefits of reducing food-borne Illness
are large, and thus have justified the imposition of HACCP through regulation. Establishing the
critical limits that must be met at each CCP for microbial contamination, however, may require
marginal cost-benefit analyses, where the value of reducing risk to very low levels is weighed against
the additional costs. This type of analysis is not evident in the preliminary impact assessment oi
USDA's proposed rule, and exploration of these trade-offs would surely improve the design of
regulation.