The cost of compliance with the Pathogen Reduction Hazard Analysis Critical Control Program (PR/HACCP) rule of 1996 has been controversial from the time it was first proposed. Recent survey evidence indicates costs of about $0.01 per pound. These estimates may capture actual costs but do not indicate how different components of the rule itself, such as HACCP tasks, and indirect influences, such as plant size, affect costs differently. The purpose of this paper is to empirically examine these direct and indirect influences. Preliminary results suggest that plant size has a small, if any influence on costs. The most substantial direct cost is the cost of performing sanitation and tasks associated with a plant's HACCP process control plan.


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