17 January 2008

Procedure is king

More from Bad Food Britain:
'Hazard Analysis Critical Control Point' (HACCP) ... focuses on identifying the 'critical points' in a process where food safety problems - hazards - could arise... What HACCP boils down to is a system of checklists, form filling and record keeping. ... This system creates a paper trail so that in the event of a problem, the companies or producers implicated can demonstrate that they did their bit and walk away blameless, plausibly denying responsibility. ... A supermarket that poisoned customers by selling contaminated chicken... could use HACCP to show that its suppliers followed correct procedures so it was not at fault.
The overriding objective - the one that permeates the entire system - has little to do with food safety and everything to do with protecting oneself from disciplinary proceedings or lawsuits. There's a similar confusion in other policy areas. Here is Bruce Schneier on airport security:
Surprising nobody, a new study concludes that airport security isn't helping: "A team at the Harvard School of Public Health could not find any studies showing whether the time-consuming process of X-raying carry-on luggage prevents hijackings or attacks. They also found no evidence to suggest that making passengers take off their shoes and confiscating small items prevented any incidents."

And: "The researchers said it would be interesting to apply medical standards to airport security. Screening programs for illnesses like cancer are usually not broadly instituted unless they have been shown to work."

Note the defense by the TSA: "'Even without clear evidence of the accuracy of testing, the Transportation Security Administration defended its measures by reporting that more than 13 million prohibited items were intercepted in one year,' the researchers added. "Most of these illegal items were lighters.'"

This is where the TSA has it completely backwards. The goal isn't to confiscate prohibited items. The goal is to prevent terrorism on airplanes. When the TSA confiscates millions of lighters from innocent people, that's a security failure. The TSA is reacting to non-threats. The TSA is reacting to false alarms. Now you can argue that this level of failures is necessary to make people safer, but it's certainly not evidence that people *are* safer.
Again, rational policy is subordinated to procedure. It can't work: we need diverse approaches that can adapt to changing circumstances. Such pluralism are anathema to centralized policymaking. But what government policymakers can do is specify target objectives, and contract out their achievement to the market. Actions should serve outcomes - not procedures. A Social Policy Bond regime would ensure that all actions would aimed at achieving the social and environmental goals set for it by government. Being freely marketable, they would encourage the adaptive, diverse solutions that big, complex social and environmental problems demand.

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