The Bush Administration's Interagency Working Group (IWG) is pushing a flawed food safety system that prioritizes trade considerations over public health. Many of the IWG's recommendations and actions are designed to reduce import inspection and testing and instead emphasize safety certification of foreign import facilities. The recommendations rely largely on exporters and importers to implement voluntary prevention controls against food and feed contamination. This approach extrapolates internationally the highly criticized U.S. food safety management system whose breakdown resulted in large meat product recalls in 2007.

Many of the regulatory tools proposed by the IWG have exposed U.S. consumers to unsafe or potentially unsafe food when implemented domestically. The Administration's proposal was developed with the help of industry to avoid greater rates of physical inspection and testing. This off-shoring and outsourcing of product safety provides another layer of plausible deniability for corporate liability prevention.