Cheng Chih-wen's Perspective: When Companies Are Both Players and Referees - Food Safety Inspection Must Be Centralized

A barrel of edible oil shipped from a factory in Taichung may be sent to restaurants in Taipei, food processing plants in Taoyuan, and catering companies in Kaohsiung, eventually ending up in kitchens across Taiwan. The oil has already been circulated nationwide, and the risk does not stop at the county boundaries; however, the monitoring responsibility is divided among different local governments based on the factory's location. This is the biggest contradiction in Taiwan's food safety system: products are nationalized, but monitoring is localized. After the Chungli Oils event, some legislators questioned that the last time the Taichung City Government actually took samples of the company's oil products for testing was nearly 800 days before the incident. The city government stated that during this period, they had conducted multiple factory inspections and reviewed the company's production records and self-inspection reports. The problem is that "inspection" is not the same as "sampling." The government checking the factory environment, documents, and reports submitted by the company is a completely different management behavior from government personnel directly taking samples from the raw material tanks, process tanks, or product tanks for testing. What the people really want to know is not which unit can legally do the least, but why a large-scale oil product company whose products are circulated nationwide can go for a long time without undergoing direct government sampling. The biggest loophole in self-inspection is who decides the samples. There is a basic principle in management: Garbage in, garbage out. If the input is not trustworthy, the output cannot be trustworthy. A third-party laboratory can only certify whether the bottle of oil sent to the laboratory is qualified; it cannot certify that this bottle of oil truly represents the entire oil tank, the entire batch of products, or the annual shipment. If the samples are selected by the company itself, the inspection time is decided by the company, and the government only checks the final qualified report, it is like letting students create their own questions, choose the simplest ones, and then submit the answers to the teacher for grading. The core of inspection is not just "who is responsible for inspection," but also includes: who decides which batch to sample? Who takes samples on-site? From which position in the oil tank is the sample taken? How are the samples sealed, transported, and handed over? Is the first unqualified result completely preserved? Companies can conduct self-inspection, but they cannot be both players and referees. Local inaction is a result induced by the system. Large-scale oil product companies' products are circulated nationwide, but the monitoring cost is mainly borne by the local government where the factory is located. Local governments have to bear the burden of manpower, inspection fees, corporate pressure, and political risks; once monitoring fails, the loss is jointly borne by consumers across Taiwan. In other words: the sampling cost is borne by one county or city, but the failure cost is borne by the entire Taiwan. Local governments can say that the inspection items are planned by the central government; the central government can say that the first-line inspection is the responsibility of the local government; and the company can say that they have completed the legally required self-inspection. In the end, the central government has policies, the local government has records, and the company has reports, but perhaps no one has actually taken an unknown sample from the oil tank for testing. This is not a problem of whether a single civil servant is diligent, but a governance loophole that inevitably appears after responsibility is dispersed. The EU, the United States, and Japan all require food companies to establish HACCP, hazard analysis, raw material management, traceability, self-inspection, and recall systems. However, corporate autonomy does not mean that the government has withdrawn from official sampling. The EU requires competent authorities to carry out official control, sampling, and laboratory analysis based on risk; the US FDA can directly take samples of raw materials, in-process products, finished products, and environmental samples; Japan also has the government establish monitoring plans to carry out sampling inspections of domestic and imported food. Although their administrative divisions are not exactly the same, the principle is consistent: companies are responsible for daily control, and the government is responsible for independent verification. Taiwan cannot only learn the four words "corporate autonomy" but ignore the fact that behind them, there must be government sampling, laboratory certification, professionals, and legal responsibility. Source sampling of large-scale oil products should be returned to the central government. Taiwan's territory is small, but large-scale oil products are a nationwide supply chain. The central government should establish a dedicated oil inspection unit to uniformly manage the source sampling of large-scale oil factories. The central government should grasp the list of operators, sources of raw materials, oil tank data, production batches, and product circulation, and arrange unannounced inspections based on the scale of the enterprise, historical violations, and raw material risks. The sampling scope should include raw material tanks, process tanks, finished product tanks, and market products; each sample should be divided into inspection samples, re-inspection samples, and sealed samples, and the entire process of sealing, transportation, and handover should be completely recorded. Local governments can still manage restaurants, markets, and small food operators, but the source inspection of large-scale oil factories must be ultimately responsible by the central government. Inspection personnel must be certified, and corporate laboratories must be accredited. Currently, corporate internal inspectors do not necessarily need to obtain a unified food safety inspection certificate; internal laboratories do not necessarily accept the same external accreditation as third-party laboratories. This loophole must be filled. The government should establish a "food inspection professional personnel" national certificate. Sampling, instrument operation, data interpretation, and report signing for large-scale oil products and high-risk food operators must be carried out by certified personnel. The certificate content should cover food chemistry, instrument analysis, contaminants, sampling technology, quality management, data integrity, food regulations, and professional ethics, and they should regularly receive training, ability tests, and certificate renewal. Internal laboratories of large enterprises should also be mandatory to obtain ISO/IEC 17025, TFDA, or equivalent accreditation. Instruments must be regularly calibrated, methods must be verified, and original chromatograms, standard curves, first results, re-inspection records, and modification tracks must be preserved. Companies cannot just keep a beautiful qualified report. Food safety fraud cannot only be punished to the company, because the company will not go to jail, the real person who gave the order is a person. Replacing samples, forging batch numbers, deleting original data, hiding the first unqualified results, or instructing subordinates to modify reports should all be pursued for criminal responsibility of the company's responsible person, manager, laboratory personnel, and direct actor. In serious cases, their qualifications should be revoked, and they should be prohibited from serving as managers in the food industry or laboratories again. At the same time, the "Food Safety Act" must establish a whistleblower system. Those who first discover problems within the company are usually inspectors, production personnel, procurement, or warehouse managers. The government should allow anonymous reporting, prohibit dismissal, transfer, pay cuts, or lawsuit retaliation, and provide identity protection, legal assistance, and whistleblower rewards. Without whistleblowers, the government can only see the information that the company is willing to provide. Food safety responsibility cannot be further fragmented. Taiwan must completely revise the "Food Safety and Hygiene Management Act": the central government uniformly manages the source sampling of large-scale oil products; corporate inspectors obtain national certificates; corporate laboratories are mandatory to be accredited; original data is completely preserved; individual criminal responsibility is pursued for fraud; and a whistleblower system with rewards and protection is established. Otherwise, every time a food safety incident occurs, the same script will be seen: the company says it has completed self-inspection, the local government says it has acted according to central regulations, and the central government says the first-line responsibility belongs to the local government. Everyone has a reason, but no one takes full responsibility for the oil that the people have eaten. When a barrel of oil can be circulated throughout Taiwan, its safety must be borne by the central government with nationwide consistent and non-transferable final responsibility. *The author is the chairman of the Chinese Taipei Applied Management Association and a Ph.D. in Business Administration from Nan'ao University.