I heard it at least once a week for ten years. Sometimes more. I would be standing in a plant, reviewing records or observing a process, and I would ask a question. Not a gotcha question. Just a straightforward question about why something was done a certain way. And the answer, delivered with total confidence, was almost always the same.
We have always done it this way. And we have been fine.
That sentence sounds reasonable. It sounds like stability. It sounds like a plant that knows what it is doing. But after ten years as a USDA Consumer Safety Inspector, I can tell you that sentence is where more food safety problems begin than any single contamination event, equipment failure, or staffing shortage I ever encountered.
It is the sentence that keeps plants from fixing what is broken. And the worst part is, the people saying it usually believe it.
What Fine Actually Means
When a plant manager says they have been fine, what they usually mean is that they have not had a major enforcement action. No recalls. No suspensions. No front page news stories. And by that measure, they are right. They have been fine.
But fine and compliant are not the same thing. And compliant and excellent are not even in the same zip code.
I have walked into plants that had been operating for years with the same Noncompliance Records repeating on a cycle. The same pre-op findings showing up every few months. The same CCP monitoring gaps appearing in their logs quarter after quarter. And every time I brought it up, the response was some version of the same thing: we know about that, we handle it when it comes up, it has never been a real problem.
But it is a real problem. It is just a problem that has not reached its full consequence yet. Every repeat NR is a data point. Every pattern of noncompliance builds a case. And when FSIS decides to conduct a Food Safety Assessment at your facility, they are looking at trends. FSIS Directive 5000.1 describes how inspection program personnel verify compliance over time.
That is when fine stops being fine.
Why Plants Get Stuck in This Mindset
I do not blame the people who say it. Running a food plant is hard. The margins are thin. The days are long. The regulatory burden is real. When you have a system that is keeping the doors open and the product moving, the last thing you want to do is tear it apart and rebuild it.
And there is a survivorship bias at work. If a plant has been operating a certain way for five or ten or fifteen years without a shutdown, it is natural to conclude that the system must be working. What they do not see are all the plants that operated the exact same way and eventually did get hit.
There is also a generational knowledge problem. In a lot of plants, the way things are done was established by someone who is no longer there. The original logic behind the process has been lost. The current team inherited the system and kept running it because it was what they were trained on.
So the system persists. Not because it is the best system. Because it is the familiar system. And familiar feels safe, even when it is not.
The Three Things Plants Really Mean When They Say It
Over ten years of inspections, I started to recognize that the sentence had different meanings depending on who was saying it and when.
The first version is genuine ignorance. The plant does not know that what they are doing is a problem. Their HACCP plan has not been reassessed in years. Their prerequisite programs have drifted from reality. Their corrective action process is incomplete but nobody has pointed it out forcefully enough to trigger a change. What Inspectors Actually Look For covers the record categories where these gaps usually show up.
The second version is cost avoidance. The plant knows there is a better way to do things, but the better way costs money. New equipment, new software, additional training, maybe an extra person on the QA team. The math does not work because they are comparing the cost of improvement against a risk they have not experienced yet.
The third version is cultural resistance. This is the hardest one. The plant knows. The QA manager knows. Even the line supervisors know. But ownership or senior leadership has made it clear that food safety is a box to check, not a system to invest in.
What an Inspector Actually Hears When You Say It
When a plant tells an inspector that they have always done it this way and they have been fine, the inspector does not hear confidence. The inspector hears a plant that is not self evaluating. A plant that is not reviewing its own system critically. A plant that is relying on the absence of consequences as proof that the system works.
That distinction matters because it changes how the inspector approaches everything that follows. If I ask you why your corrective action records are missing the preventive measure component and you tell me that you have always done it this way, I now know two things. I know the records are deficient. And I know the plant has no mechanism for catching its own deficiencies.
Inspectors evaluate systems, not just paperwork. When I see a plant that is actively reviewing its own performance, catching its own gaps, and making adjustments, I have confidence in that operation even if it is not perfect. Nobody expects perfection.
How to Break the Cycle
The good news is that breaking out of this mindset does not require a complete overhaul. It starts with one decision: to look at your own system the way an inspector would look at it.
Pull your Noncompliance Records from the last twelve months. Read them together. Are there patterns? Are the same issues coming up in the same areas? Are your corrective actions actually preventing recurrence, or are they just addressing the immediate problem and moving on? If the same finding shows up three times in a year, your corrective action process is not working.
Then look at your HACCP plan. When was the last time it was genuinely reassessed? Not rubber stamped. Actually reviewed against the way your plant operates today. If you have added products, changed suppliers, installed new equipment, or modified your process flow since the last reassessment, you are overdue. 9 CFR 417.4 is the regulation behind validation, verification, and reassessment.
Then look at your prerequisite programs. Walk the floor with your SSOPs in hand. Read what the document says and compare it to what is actually happening. If there is a gap between the two, close it. Either update the document or update the practice. But do not leave the gap open and hope nobody notices.
And finally, start reviewing your own records before anyone else does. Every day. Not once a week. Not when you hear an audit is coming. Every day. The plants that pass inspections consistently are the ones where someone looks at yesterday's records first thing this morning.
The Bottom Line
We have always done it this way is not a food safety strategy. It is the absence of one. And the fact that nothing bad has happened yet is not evidence that the system works. It is just evidence that the consequences have not arrived yet.
The plants that lead this industry are the ones that stopped saying that sentence and started asking a different question: is there a better way to do this? Not because a regulation forced them to. Not because an inspector wrote them up. Because they decided that fine was not good enough.
That is the standard I held myself to as an inspector. And it is the standard I built U.S. AgriDocs around. Not to replace the people doing the work. To give them a system that actually keeps up with what the work demands.
John Parisi is the co-founder of U.S. AgriDocs and a former USDA Consumer Safety Inspector with ten years of federal inspection experience.