The Taming of the Stew: Regulatory Intermediaries in Food Safety Governance

670 ANNALS of the American Academy of Political and Social Science 78 (2017)

26 Pages Posted: 1 Jun 2017

See all articles by Timothy D. Lytton

Timothy D. Lytton

Georgia State University College of Law

Date Written: May 29, 2017


Efforts to manage the risk of bacterial contamination in food comprise a complex system of public and private institutions that employ a combination of laws, market incentives, and social norms. Throughout the system, regulatory intermediaries perform essential functions. They gather information, convey signals, clarify norms, verify compliance, enforce mandates, and channel feedback that leads to improvement over time. Relationships among rule-makers, intermediaries, and targets of regulation (R-I-T relationships) provide a manageable unit of analysis from which to begin mapping the enormous volume and variety of regulatory interactions out of which the system is constructed. The RIT model thus identifies a basic building block of complex regulatory systems.

The analysis begins with several examples of R-I-T relationships within food safety governance and explains how intermediaries enhance the efforts of rule-makers to govern targets. It then examines various ways in which rule-makers employ additional intermediaries to address agency problems between the rule-makers and the initial intermediaries upon whom they rely to govern targets of regulation. The initial intermediaries are thus treated as targets of regulation to assure that they are reliably performing their intermediary role. In some variations, entire multi-actor R-I-T relationships can serve as additional intermediaries between rule-makers and initial intermediaries.

In applying the RIT model to advance understanding of the widespread reliance on different types of intermediaries throughout food safety governance, one must be careful not to mischaracterize the nature of rulemaking within the system. The network structure of food safety governance makes it misleading to attribute the origin of governance standards to authoritative “rule-makers.” Instead, standards emerge out of interactions among individuals and institutions throughout the network, and they evolve through feedback and learning. The RIT model can avoid confusion — without compromising its explanatory power with regard to reliance on intermediaries — by favoring the term “rule-maker” with “regulator” where appropriate. Consequently, one might define a regulator in broad terms as an actor that relies on rules — not necessarily of its own making — to influence the conduct of targets of regulation.

Keywords: Food Safety, Regulatory Governance, Third-Party Auditing, Intermediaries, Network Theory

JEL Classification: I10

Suggested Citation

Lytton, Timothy D., The Taming of the Stew: Regulatory Intermediaries in Food Safety Governance (May 29, 2017). 670 ANNALS of the American Academy of Political and Social Science 78 (2017), Available at SSRN:

Timothy D. Lytton (Contact Author)

Georgia State University College of Law ( email )

P.O. Box 4037
Atlanta, GA 30302-4037
United States


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