Selection of Food Safety Standards

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Selection of Food Safety Standards Bo-Hyun Cho Centers for Disease Control and Prevention Neal H. Hooker The Ohio State University Selected Paper prepared for presentation at the American Agricultural Economics Association Annual Meeting, Long Beach, California, July 23–26, 2006 Copyright 2006 by Bo-Hyun Cho and Neal H. Hooker. All rights reserved. Readers may make verbatim copies of theis document for non-commercial purposes by any means, provided that this copyright notice appears on all such copies. This paper is a part of Bo-Hyun Cho’s dissertation in his private capacity. No official support or endorsement by the Centers for Disease Control and Prevention, Department of Human and Health Services is intended nor should be inferred.

Transcript of Selection of Food Safety Standards

Page 1: Selection of Food Safety Standards

Selection of Food Safety Standards

Bo-Hyun Cho

Centers for Disease Control and Prevention

Neal H. Hooker

The Ohio State University

Selected Paper prepared for presentation at the American Agricultural Economics

Association Annual Meeting, Long Beach, California, July 23–26, 2006

Copyright 2006 by Bo-Hyun Cho and Neal H. Hooker. All rights reserved. Readersmay make verbatim copies of theis document for non-commercial purposes by anymeans, provided that this copyright notice appears on all such copies.

This paper is a part of Bo-Hyun Cho’s dissertation in his private capacity. No official support orendorsement by the Centers for Disease Control and Prevention, Department of Human and HealthServices is intended nor should be inferred.

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Abstract

Food safety regulations are evolving to more performance-based regimes in which firms

have greater flexibility and responsibility for adopting effective controls. Within this

context, this paper compares performance and process standards modeling the vari-

ability of industry-level compliance and therefore the resultant level of food safety.

Monte Carlo simulations are conducted manipulating five factors: the variances of

input use of efficient and inefficient firms, the proportion of inefficient firms in the

industry, the mean of the error term for inefficient firms, and the policymakers’ level

of risk aversion. Results suggest that process standards may be preferred over per-

formance standards when inefficient firms prevail in the industry, when input use

is highly variable and when the regulator pays less attention to the variability of

industry-level compliance and more to the level of the standard.

Keywords: Performance Standards, Process Standards, Food Safety, Monte Carlo

Simulation

JEL Classification: Q180 Agricultural Policy & Food Policy

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Introduction

The design of socially optimal food safety standards has received increased atten-

tion in recent years. Food safety regulatory standards take three forms according to

Antle (2000)1; process (design), performance and combined standards. Performance

standards can be described as controls that regulate the upper limit (or maximum

tolerance level) of risk in food. Process standards require the firm to use at least a

minimal amount of a risk control input. In practice, most food safety regulations do

not neatly fall into one single category. Rather, regulations combine elements of both

process and performance standards as discussed in Unnevehr and Jensen (1996).

In this paper, we focus on two aspects of regulatory standards - control through

inputs or outputs. As one option a food safety regulation may apply a performance

standard requiring all food (output) to at least meet the required criterion2. Con-

versely, a process standard can be the basis of a regulation with a requirement that

firms use, at least, a particular level of a certain risk control input such as a steril-

izer, washing fluid, hot water or irradiation equipment. Comparing these standards,

1Standards can also be defined based on the degree of intervention. For example, Henson and

Heasman (1998) distinguish target, performance and specification standards. Target standards im-

pose liability for prespecified harmful consequences caused by products while no specific prescription

of the product is made. Performance standards dictate the safety level for the product while allowing

the firm to choose the method of production. Specification standards require either the product or

its’ production process or both meet a predefined goal.2An extreme example is the use of zero-tolerance standards for pathogens such as Listeria mono-

cytogens (Institute of Medicine, National Research Council, 2003)

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economists seem confident of the superiority of performance standards in terms of

cost minimization (Antle, 1996), simply because performance standards allow for a

flexible adjustment to the firm’s unique production environment leading to lower dis-

tortions in the economy 3. From the perspective of social welfare optimization, the

argument is valid if benefits under two alternative standards are the same. This pa-

per examines if the two different standards provide the same level of benefit from the

viewpoint of food safety risk reduction.

Motivation

The model and motivation are an effort to characterize a regulator’s comparison of

these standards. Most of the existing literature has focused on incentives for compli-

ance by firms. Naturally, the standard with the lower compliance cost is preferred.

However, the regulator here is assumed to be more interested in the public health

impact of standards. That is, unable to observe the actual compliance behavior of

firms (e.g., managerial intensity or effort), the regulator needs to select a standard

which minimizes the probability of foodborne illness outbreaks and sporadic events.

Thus, the regulator is assumed to act like an investor balancing a portfolio, choosing

a standard less likely to result in deviation by firms in the relevant industry. The

approach applied here to compare the effectiveness of standards is therefore borrowed

from the field of financial economics: a safety-first rule. This is relevant as food

3See Marino (1998).

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safety policy has a goal of not only minimizing the level of risk (standard) but also

the deviation around the standard given the stochastic nature of most food safety

attributes4.

Among other risk measures used in the area of financial economics, the safety-

first rule is simple and conservative, though old. As a key advantage, the measure

is distribution-free, providing an upper-bound of the probability of violation of the

standard. A process standard is assumed different from a performance standard in

the sense that the former requires a minimum level of input use directly affecting the

reduction of food risk. Contrast this to a performance standard which regulates out-

put quality. Therefore, a “truncated” distribution of input use supports the process

standard. It is obvious, therefore, that a process standard results in a lower (or no

greater) level of food safety risk. However, to compare the degree of public health pro-

tection, higher moments of the resultant food safety distribution must be assessed,

which quickly becomes intractable for even the most straightforward of standards.

Hence, simulation results are provided here to illustrate potential factors which may

influence the optional standard design.

Previous Research

Besanko (1987) showed that in an oligopolistic market the economic impact of dif-

4During food production, manufacturing, distribution and preparation, microbial pathogens may

be introduced, reduced or redistributed through cross-contamination while chemical and physical

hazards may be introduced or eliminated in a different manner.

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ferent standards depends on demand and cost functions. Marino (1998) presented

evidence that process standards are preferred to performance standards if an asym-

metric information environment exists between the firm and the regulator. Recently,

Hueth and Melkonyan (2003) argued that process standards are different to design

standards in the presence of mandatory monitoring and asymmetric information.

Their approach compares expected social surplus under each standard to determine

the most efficient form. The model presented here is different, providing a focus on

possible stochastic deviations from the targeted level of food safety risk. When reg-

ulators evaluate or compare policies, the expected level of risk and variance of risk

control should be carefully considered. This situation is analogous to choosing a port-

folio of risky assets in financial economics. Various methods such as the safety-first

rule, mean-variance, stochastic dominance and other expected utility models can be

applied, as described below.

Models

The Setting

Assume that there are a finite number of firms producing food (N). Accordingly, N

types of firms (θ) are realized when drawn from a random variable Θ. The regulator

cannot tell which firm is of which type, but is assumed to know the distribution

of the random variable Θ. Assume that the targeted level of food safety risk s∗ is

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given exogenously based on a science-based food safety risk assessment. Following

Lichtenberg and Zilberman (1988), the regulator is assumed to select a standard

which minimizes social cost while limiting the probability of violation of the food

safety target (s∗). Formally,

mini SCi (1)

subject to prob(si ≤ s∗) ≤ 1− p

where i ∈ {process, performance}, SCi refers to the resultant social cost under

a regulatory standard i, and si refers to the observed level of food safety. The op-

timization problem in equation (1) suggests which food safety standard minimizes

social cost given a certain level of food safety risk (or acceptable level of protection).

A simple cost-effectiveness analysis applies such a selection rule when comparing al-

ternatives. However, it is more common to see regulatory agencies being provided

a budget to implement a range of control policies. This is like the dual of the op-

timization problem: which standard minimizes the probability of violation given a

budget constraint? Furthermore, if the ex-post loss resulting from foodborne illness

is included within a more complete cost-benefit framework, the regulator is encour-

aged to select the policy with the lowest possibility of safety deviations. Such an

approach allows for deviations from the target, which may result in a food safety

recall or life-threatening outcomes such as foodborne illness outbreaks. The standard

selection problem becomes a broader comparison of risk, specifically, the probability

of violation under each standard.

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Assumptions

Two types of players - the regulator and firms - are assumed throughout this paper.

Firms have multioutput technologies producing food and food safety risk jointly. Cost

minimization determines their optimal input level based on the targeted safety level

(s∗) set by the regulator.

Assumption A1 (Cost Minimization). The firm minimizes its cost constrained by a

production technology g(z|θ). Formally,

minz

wz + λ(s∗ − g(z| θ)) (2)

Input demand z∗ is a function of input prices w, s∗ and the firm type θ, z∗ =

z(w, s∗| θ). The optimal value function, a cost function, depends on input prices, the

targeted safety level and the type of firm, C∗ = w · z∗ = C(w, s∗| θ).

Asymmetric information about the firm’s technology is also assumed: the regula-

tor does not know which firm has the greater ability to apply a certain food safety

technology but does know the technology adopted. The food safety technology is

represented as a risk control function.

Assumption A2 (Risk Control Function). Food safety technology can be represented

as the following risk control function, gs.

s = gs(z| θ) (3)

where s is the resultant level of safety produced by the firm, z refers to risk control

inputs and θ is an index of the type of firm, determining the efficiency of risk control

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achieved by a particular technology. The risk control function gs is non-decreasing in

input level z and type θ, ∂gs

∂z> 0, and ∂gs

∂θ> 0, respectively.

Firms are assumed to have different marginal products for their risk control inputs.

This assumption allows heterogeneity in firms technology. Efficient firms are assumed

to have higher marginal productivities of risk control input than inefficient firms 5.

Assumption A3 (Efficient Food Safety Technology). For θ0 > θ1,

∂gs

∂z

∣∣∣z=z∗, θ0

>∂gs

∂z

∣∣∣z=z∗, θ1

(4)

.

Risk Measures

As introduced above, this study compares the resultant levels and distributions of

food safety risk for process and performance standards. The financial decision-making

literature provides a large range of risk measures6. In quantitative studies, due to

limited knowledge of the true distribution, risk is often measured using moments

such as mean, variance, or a combination of both 7. Among other factors, it is

5Such heterogeneity can arise through differences in managerial efficacy or optimization error.6It is important to distinguish two concepts of risk: food safety risk and risk as a quantitative

measure. Food safety risk arises from the presence of hazards in food. In this paper the probability

of observing foodborne illness is modelled as a measure of risk.7For example, Domar and Musgrave (1944) formulate a quantitative measure of risk taking into

account all possible negative or relatively low probability outcomes. A dispersion parameter such

as variance or standard deviation is used as a risk index. A semi-variance measure uses a similar

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important to measure risk resulting from the two different standards in a conservative

sense. Thus, Roy’s Safety First rule is used to provide one method to compare

probability. Roy (1952) suggests such a “safety first” rule for regulators trying to

avoid a “disaster.” His risk measure is represented in terms of the probability that

the outcome will be lower than a constant s∗, the acceptable level of risk determined by

the policymaker. However, given limited knowledge of the distribution, in particular

the mean (E(S)) and variance (σ2S) of outcomes, it is useful to elaborate on this

measure using Chebychev’s inequality to represent the probability of a “bad” event8.

An advantage of the safety first rule is that it provides an upper bound probability

of violation of the targeted food safety level. Therefore, using the safety first rule the

different distributions of food safety risk can be compared. More interestingly, the

risk measure allows for the interpretation of consequences of differences between the

two standards in terms of the probability of violation.

prob(S ≤ s∗) ≤ σ2S

(E(S)− s∗)2(5)

σ2S

(E(S)−s∗)2 is the upper bound of the probability of a disaster which can be used

to select the least risky standard. The greater the upper bound, the riskier the

standard. Intuitively, assuming the same mean values of two different distributions,

formula replacing the mean with a constant in order to consider only negative deviations from the

constant (Levy, 1998).8This inequality is useful as it provides a universal bound for probability regardless of the distri-

bution of the random variable (Casella and Berger, 1990).

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the distribution with the larger variance will be riskier. For distributions with the

same variance, a larger mean value suggests a less likely disastrous outcome.

Recall that the optimal risk control input demand z∗(θ) depends on the type

of firm which is uncertain to the regulator. Suppose that the probability density

function of z, fZ(z) is also unknown to the regulator. For simplicity, assume that the

risk control function is a monotonic transformation of the random variable, Z. Then:

pr(z ≤ z∗) =

∫ z∗

0

fZ(x)dx (6)

pr(s ≤ s∗) =

∫ g−1(s∗)

0

fZ(g−1(y))d

dyg−1(y)dy (7)

Equations (6) and (7) show the probabilities that input use or the resultant safety

level respectively are lower than the predetermined targeted levels in terms of the

density function. Without knowing fZ(z) it is impossible to assess which standard is

riskier. In order to compare the upper bound of each standard, the expected value

and variance of the safety level under each regime must be calculated. Conceptually,

these measures can be calculated as follows. First, under the performance standard,

the expected value (Epf (S)) and variance (σ2pf ) are derived as follows.

Epf (S) =

∫ ∞

0

g(x)fZ(x)dx (8)

σ2pf =

∫ ∞

0

(g(x)− Eg(Z))2fZ(x)dx (9)

Since there is no restriction on input usage, the expected value and variance of the

safety level are calculated on the domain of Z.

However, under a process standard, because of the minimum input use require-

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ment, the safety level is derived on [z∗, ∞]. Thus, the expected value (Epc(S)) and

variance (σ2pc) are defined as follows.

Epc(S) =

∫ ∞

z∗g(x)fZ(x)dx (10)

σ2pc =

∫ ∞

z∗(g(x)− Eg(Z))2fZ(x)dx (11)

Note that since g(z) is assumed to be a non-stochastic, monotonic transformation the

process standard is equivalent to the case of a combined standard. The comparison of

expected values and variances depends upon the parameter (z∗) and the distribution

(fZ(z)). To highlight the role of these factors a Monte Carlo simulation is presented

below.

Monte Carlo Simulations

Procedures

As assumed above firm type θk is exogenous, known to the firm but not perfectly

known to the regulator. The regulator is assumed to observe, imperfectly, the level

of risk-control input demands or final food safety level. For the purpose of the Monte

Carlo simulation a linear error term is assumed for the input demand function :

z∗(θk) = z∗ + θk for k = 1, 2, ... , N . Suppose that N firms are partitioned into two

groups: n1 inefficient firms and (N −n1) efficient firms. Accordingly, the distribution

of θi is assumed to differ for two different groups; θi for (N − n1) efficient firms and

θj for n1 inefficient firms. For simplicity, the risk control function is assumed to be

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gs(z) = log10(z). The expected value of θj is assumed to be larger for inefficient firms9.

Finally, the resultant level and dispersion of food safety is calculated by inserting z,

drawn from the simulated distribution, into gs(z).

With these assumptions, sample means and variances of the safety level under a

performance standard can be calculated using the following equations based on N

randomly drawn input levels z∗θk.

Epf (S) =1

N

N∑

k=1

gs(zk) (12)

σ2pf =

1

(N − 1)

N∑

k=1

(gs(zk)− Epf (S))2 (13)

By the same token, the mean and variance of the safety level under a process stan-

dard can be calculated using N randomly drawn input levels ztr using a truncated

distribution at the critical value, z∗. An acceptance-rejection method is applied 10.

9The marginal product of the risk control function is 1/z so, by assumption 3, z∗(θi) = z∗+ θi >

z∗ + θj = z∗(θj). Therefore, θi > θj . To reflect this result, a larger mean for θi is assumed.10This method is used when the functional form of a distribution is difficult or time consuming

to generate random numbers. Assuming a “source” distribution considered close to the true dis-

tribution, draw a number from the source distribution then compare how close it is to the true

distribution. If considered close enough, accept the draw. Otherwise, repeat the same procedure.

For a detailed algorithm, refer to Martinez and Martinez (2001).

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Epc(S) =1

N

N∑

k=1

gs(ztrk ) (14)

σ2pc =

1

(N − 1)

N∑

k=1

(gs(ztrk )− Epc(S))2 (15)

The experiments were designed to vary five parameters: the mean value of the

error term for inefficient firms, the variances of distributions of θi and θj (for efficient

and inefficient firms respectively), the proportion of inefficient firms in the industry

(ratio = n1

N× 100) and a risk-aversion parameter for the policymaker (h). The first

four parameters are related to characteristics of the industry of which the regulator has

a limited knowledge. The risk-aversion parameter represents the regulator’s attitude

toward risk from foodborne illness.

The distributions of θ and θ represent stochastic variations of risk control input

use by firms. The mean value of the error term for inefficient firms is set to be 110,

150 and 190 percent of the mean value of the distribution for efficient firms, 100. The

variances of the distributions represent the dispersion of risk-control inputs used by

the firms.

The proportion of inefficient firms in the industry reflects how many firms are

inefficient in controlling food safety risk, which can be determined through facility

inspection or monitoring. The parameter h captures the level of risk-aversion of the

regulator. Baumol’s risk measure (µ − h · σ) incorporates not only the mean value

of the resultant safety level but also its variability (Baumol, 1963). For larger h,

Baumol’s risk measure decreases, which penalizes deviations from the mean value.

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When determining the targeted food safety level, a lower level of h suggests stricter

food safety control.

The variance of distributions of θ and θ is varied between 10 and 100 in units of

10. The proportion of inefficient firms in the industry ranges over 10 %, 30 %, 50 %,

70 %, to 90 %. The targeted safety level is assumed to be determined by µpf −h ·σpf

where, for this experiment, three different values of h are evaluated: 1, 3, and 5 11.

Based on these simulations, Roy’s risk measures are calculated for each standard.

This experiment is repeated 10,000 times using the Statistics Toolbox 4.0 installed in

MATLAB.

Results

Not surprisingly, resultant levels and dispersions of food safety risk are influenced by

all five parameters. Two presentations of the comparative risk measures under each

of the standards are provided - three-dimensional figures and a table, with illustrative

examples of parameter values.

First, the surfaces of Roy’s risk measures with varying mean values of risk-control

input use by inefficient firms are reported in Figures 1, 2, and 3. In each Figure,

the X-axis presents the variance of distribution of θ for inefficient firms while the

variance of distribution of θ assigned to efficient firms are represented on the Y-

11A value of h=0 implies that the regulator is risk neutral. In this experiment, the targeted level

is equal to the mean of resultant food safety level under a performance standard. Consequently, the

denominator of Roy’s risk measure becomes zero.

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axis. Both axes range from 10 to 100. The Z-axis plots the Roy’s risk measures for

each standard. Thus, the surfaces represent differing risk measures corresponding to

changing variances. For the purpose of illustration 10, 50 and 90 % proportions of

inefficient firms in the industry are presented here. Note that under a performance

standard Roy’s risk measure simply becomes 1h2

12. Therefore, the surface becomes a

flat plane under a performance standard providing an easy comparison for the factors

which affect the relative risk measure under a process standard.

A review of the various Figures reveals some notable patterns. First, as the mean

of the distribution of risk-control input use by inefficient firms increases, Roy’s risk

measure under a process standard decreases. That is, when inefficient firms prevail,

a process standard may prove to be more effective by controlling the minimum use

of risk-control inputs. Therefore, when the regulator believes that the industry has

a considerable proportion of inefficient firms, optimal risk control occurs through a

process standard. However, it is also notable that there are two cases when a per-

formance standard is preferable to a process standard (Table 1). Second, as the

proportion of inefficient firms in the industry increases, so Roy’s risk measure under a

process standard also increases. Thus, compared to the results under a performance

standard, an increased proportion of inefficient firms may be more likely to harm the

safety reputation of the industry. Regarding the role of variances, when the propor-

12Recall that Roy’s risk measure is σ2S

(E(S)−s∗)2 . Substituting s∗ yields 1h2 under a performance

standard.

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tion of inefficient firms is relatively low, as the variance of input use by inefficient

firms increases, so the risk measure under a process standard increases for any given

variance of input use by efficient firms. In contrast, the process standard risk measure

decreases as the variance of input use by efficient firms increases for a given variance

of input use by inefficient firms. However, as the proportion of inefficient firms and

the variance of input use by inefficient firms increases, the process standard risk mea-

sure decreases. The result that a larger variance associated with inefficient firm’s

input use influences the risk measure relatively less occurs because under a process

standard input use is clearly regulated. Therefore, even with a higher variance the

possibility of inefficient firms controlled by a process standard using a lower level of

the risk control input is greatly restricted. Yet, even a relatively low variance and

control through a process standard may be associated with higher overall risk for

food products if the industry is dominated by inefficient firms. When a higher h is

imposed, the risk measures under a process standard become closer to those under

a performance standard. For example, when h=2, the risk measure under a process

standard exceeds those under a performance standard in some cases such as those

with a small proportion of inefficient firms when the variance of inefficient firm’s in-

put use is large and the variance of efficient firm’s input use is small. The results

suggest that a performance standard can provide a riskier situation compared to a

process standard with the same targeted safety level (s∗) under specific conditions.

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Summary and Discussion

In comparing standards, performance standards are most often preferred due to their

lower compliance costs. Yet such a comparison implicitly assumes that all standards

result in the same level of compliance or benefit. However, this paper compares the

effectiveness of risk reduction achieved by process and performance standards from

the viewpoint of a regulator with a limited administrative budget. Consequently,

unlike previous research such as Hueth and Melkonyan (2003), the approach presented

here characterizes stochastic deviations from a targeted level of safety. In addition,

this evaluation of standards focuses on the relationship between the regulator and an

industry consisting of many different types of firms while most other papers model the

compliance decision of an individual firm. By permitting such heterogeneity in food

safety technology or its management, one firm’s efforts towards compliance may not

mirror another firm’s experiences. From the viewpoint of a regulator concerned with

industry-level compliance and performance, incorporating the probability of deviation

from the standard is an important dimension of policy design and one which appears

to have received little attention. This paper is designed to explore such circumstances.

The results differ to the previously held belief that a performance standard is always

superior to a process standard. As an additional tool to traditional economic benefit-

cost analyses for policy evaluation, such a statistical simulation can help to highlight

the circumstances under which one standard may be preferred in terms of the average

resultant industry-level safety. The simulation presented here is designed to vary in

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five factors: the variances of input use, the proportion of inefficient firms in the

industry, the mean of the error term for inefficient firms, and the degree of risk

aversion of the regulators. The prescription of a socially optimal food safety standard

based on this Monte Carlo experiment is that process standards may be preferred

over performance standards when inefficient firms prevail in the industry, when input

use is highly variable and when the regulator pays less attention to the variability of

industry-level compliance and more to the level of the standard.

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Table 1: Summary of Preferred Standard based on Roy Risk Measure

The mean of the Risk Control Input Use by Inefficient Firms = 110

Proportion of Inefficient Firms

10 % 50 % 90 %

h = 1 Pc Pc Pc

h = 2 Pc Pc Pc

h = 3 Pc Pc Pc

The mean of the Risk Control Input Use by Inefficient Firms = 150

10 % 50 % 90 %

h = 1 Pc Pc Pc

h = 2 Pc Pc Pc

h = 3 Pc Pc Pf

The mean of the Risk Control Input Use by Inefficient Firms = 190

10 % 50 % 90 %

h = 1 Pc Pc Pc

h = 2 Pc Pc Pc

h = 3 Pc Pc Pf

Note: Pc suggests a process standard has a lower risk measure Pf a performance standard

is optimal.

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σ2 z j

Roy Risk Measures

020

4060

8010

0

0

20

40

60

80

1000

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0.02

0.03

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0.05

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isk

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Figure 1: Roy’s Risk Measures under Performance and Process standard when the

mean value of risk-control input used by inefficient firms is 110% of the mean value

of efficient firms

19

Page 22: Selection of Food Safety Standards

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Figure 2: Roy’s Risk Measures under Performance and Process standard when the

mean value of risk-control input used by inefficient firms is 150% of the mean value

of efficient firms

20

Page 23: Selection of Food Safety Standards

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20

40

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1

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Figure 3: Roy’s Risk Measures under Performance and Process standard when the

mean value of risk-control input used by inefficient firms is 190% of the mean value

of efficient firms

21

Page 24: Selection of Food Safety Standards

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23