Welcoming remarks for Under Secretary for Food Safety Dr. Richard Raymond, before the National Advisory Committee on Meat and Poultry Inspection, November 15, 2005, USDA South Building cafeteria conference room, Washington DC

Introduction

Good morning. On behalf of Secretary Mike Johanns, I want to welcome you to Washington. Your work here today and tomorrow on important questions regarding our move toward a more robust risk-based system will have a profound impact on the future of food safety in the United States.

NACMPI has been providing the USDA with advice and recommendations regarding meat and poultry inspection programs for nearly 25 years. In the eyes of some, the urgency and necessity of NACMPI's mission has declined in recent years. They say it is because the issues you have been asked to comment on have often not been politically charged. Today that will change.

I did not leave the comfort of Nebraska to serve just as the caretaker of a good system. Both Secretary Johanns and I want to push the envelope in food safety and public health.

I am here to issue you this challenge. Push the food safety envelope and get outside of the NACMPI box. I need you to provide me with sound advice on a number of critical questions concerning a risk-based system that can greater protect the public's health.

Signs of Progress

We all know that we can save lives through science-based policies. And as we move closer to the 100 year anniversary of the 1906 Federal Meat Inspection Act, we are able to show just how much progress we have made.

One indication of our progress has been the break in the annual cycle of multi-million pound recalls and a dramatic decline in the number of recalls each year.

This is an extraordinary accomplishment, but it is open to criticism by the naysayers. Fortunately, there are many other approaches to verifying and measuring our success, and I believe the most important indicators directly relate to public health outcomes and pathogen reduction.

We have seen dramatic downward trends occurring in our regulatory compliance testing programs for E. coli O157:H7, and Listeria monocytogenes.

• In CY 2001, 0.84% of the results were positive.
• In CY 2002, that number decreased to 0.78%;
• In CY 2003, it decreased by more than half to 0.30%; and
• In CY 2004, only 0.17% of our regulatory samples were testing positive for E. coli O157:H7.

This downward trend can also be seen in the regulatory compliance testing program for Listeria monocytogenes.

• In CY 2001, only 1.32% of the samples were positive results;
• In CY 2002, that decreased to 1.03%;
• In CY 2003, it continued to fall to 0.76%; and
• In CY 2004, the percentage of regulatory samples testing positive for Listeria monocytogenes was 0.55%.

Another significant measure of how our science-based policies and control measures implemented in the plants are affecting public health can be found in the annual FoodNet report published by the U.S. Centers for Disease Control and Prevention (CDC) every spring.

The CDC noted in its report this year that there were significant declines from 1996 to 2204 in illnesses caused by E. coli O157:H7, Listeria monocytogenes, Campylobacter and Yersinia.

Compared to the 1996-98 baseline, illnesses caused by E. coli O157:H7 decreased by 42%; Listeria monocytogenes dropped by 40%; Campylobacter fell 31%; and illnesses caused by Yersinia decreased by 45%.

I would also like to point out that we have already surpassed the Department of Health and Human Service's Healthy People 2010 objective of 1 case of E. coli O157:H7 per 100,000 people. As you can see in 2004, the CDC reported .9 cases of E. coli O157:H7 infections per 100,000 people.

The Work Ahead of Us

These are important accomplishments and we should be proud of this progress. But I also know we can do more.

We will need the new capabilities offered by an enhanced risk-based system to make improvements to our food safety and public health system that will be just as impressive.

This includes having the ability to anticipate and quickly respond to food safety challenges before they negatively impact public health. This is vital, as is a system that will allow us to use our limited resources more effectively and efficiently to further improve food safety and public health protection.

Our current system, while strong was based, in part, on the world as we knew it in 1906. It is not suited to the future realities of food safety and public health. I was recently talking to Dennis Greening, who is the district manager in Des Moines, Iowa.

I asked him to give me an example of how some plant inspectors are deployed among multiple plants and the significant amount of time spent driving between each of the plants in rural Nebraska, since I knew the turf and some of these very small plants.

Currently, these trips have to be made every day, because the Federal Meat Inspection Act requires that an inspector be at a plant every day that production takes place. Mr. Greening told me about three plants and in which towns they were located. I made a mental map, and I was concerned by the amount of driving required to visit only three plants. This is in-site inspection time that is being lost.

I am from that area of Nebraska and I know those roads well. Let me show you the route the inspector has to drive every day to inspect these three small plants. The first leg of the trip is a 50.4 mile drive to Franklin. Then after visiting that plant the inspector has to drive 13.1 miles to the next plant in Gibbon. Then the inspector gets back into the car and drives an additional 65 miles to arrive at the last plant in Beaver City.

I can tell you that on a good day, without snow or ice that is at least two-hours of driving. I don't see how two hours of driving is the very best way to improve food safety, or public health.

We need to get outside the box, outside the routine, and think creatively. While being sure to use science as our basis for ideas, and for changes that will improve food safety. We need to find a way to increase our inspectors' time in the plants, where they could, for example, spend time at a plant that is having concerns with Listeria. Allowing them to go over the FSIS compliance guidelines with the plant's management, review plant records, and even conduct environmental swabbing if appropriate. These are activities that directly relate to improving food safety.

This is what I mean when I say FSIS needs to be able to use its resources more effectively and efficiently to improve food safety or public health. I don't, nor does FSIS, have the specifics on how. That is why we are here today.

Remember, FSIS already uses a risk-based approach to food safety. Our goal is to further enhance and strengthen that system so that we are prepared for the food safety challenges of the next 100 years.

We have already taken measured steps toward this important goal. Our first step along this path toward a risk-based system was to require all meat and poultry establishments under our jurisdiction to develop implement and maintain HACCP systems.

The next step was to start the HIMP pilot program, designed to modernize on-line slaughter inspection. Through HIMP, information on product defects is gathered in real-time, helping plants make immediate corrections when problems occur in their processes.

The third step was the Listeria monocytogenes risk assessment released in 2003, which provided important data that enabled FSIS to design a final Lm rule.

As you can see the next steps are blank, but we must make them together. Today, we are initiating a dialogue on how we can best enhance our risk-based system.

Bringing our employees, the industry, and consumer organizations together to discuss these issues is one of the Office of Food Safety's most important responsibilities.

The Three-Legged Stool

I realize that for this process to succeed we are going to have to communicate, cooperate and collaborate with every one of our food safety partners. The idea of risk-based systems has been around for a long time, and attempts at change have sometimes failed. In the process, misconceptions have formed about what a more robust risk-based system is going to mean for our employees, the industry and consumers.

It is natural for people to have concerns. We are looking at making a dramatic step forward in food safety and public health. However, we must make sure that these misconceptions and concerns are addressed openly and publicly. Ensuring this process is as transparent and inclusive as possible will encourage needed communication, cooperation and collaboration.

Now I am a visual person, so let me use a visual to explain why it is so important to make sure our employees, industry and consumers work with us to enhance our risk-based approach to food safety. Think of a fully implemented risk-based system as a stool with three legs.

Employees are one leg; industry is another, as are consumers.

Now each leg of this stool has concerns that need to be addressed throughout this process that we are beginning today. But their collaboration in the creation of a robust risk-based system means they will also share in the benefits offered by a state-of-the-art food safety and public health system.

I chose this visual for a reason. Look what happens when we remove one of the stool's legs. It collapses. We must move forward together.

As you begin to work on answers to the important questions we are posing to the committee I want you to keep in mind what is at stake for us, and our important food safety partners.

Employees
Risk-based inspection provides our employees an opportunity to focus more of their work day toward activities that directly impact food safety and public health.

We understand that it will require a large investment in our employees to ensure that they have the training and skills they need to be successful in a risk-based environment. But it is an investment that I know will continue to provide food safety dividends well into the future. If they succeed, then we all succeed.

Increased training and a wider range of opportunities to make a real difference in public health will also open new avenues of career advancement to our employees. I hope that will lead to improved job satisfaction and increased employee retention and recruitment.

It will be important to keep an open dialogue between ourselves and our employees. They need to be confident that their concerns are being heard.

I want to reiterate that a risk-based system is not about making reductions to our workforce or saving money. A risk-based system is about finding a way to produce a safer product that will benefit every consumer by maximizing the effective use of our work force.

Consumers
This leads me to the importance of maintaining the public's confidence in our food safety system as we work to create a more robust risk based system. We must have safe products from plants of all sizes no matter what they produce.

Our experiences with HACCP and the Listeria monocytogenes interim final rule prove that we can further public health protection by using sound science to mitigate risk. We have seen that dramatic declines in foodborne illnesses can occur.

But as a doctor I also understand that a simple statistical decline does not fully express the human toll of those illnesses that do occur. For those affected by a foodborne illness, the statistic is 100%. We cannot be content with our present success.

However, we will also ensure that changes made to our system to reduce foodborne illnesses will be based on science. We will not make changes that will result in a product no safer than what we have currently.

Industry
To continue making needed food safety improvements, the way that inspection is currently conducted will change. However, change does not have to mean increased regulation. Industry's cooperation is key in implementing an enhanced risk-based system.

Under an optimal system, the type and intensity of inspection at an establishment will be based on performance and product.

I believe that a plant that has a spotless food safety record, science-based policies whose effectiveness has been validated, and is in full compliance with FSIS' regulations should benefit from that track record.

Our goal is to anticipate problems and to correct them before a regulatory enforcement action is ever needed. I am interested in preventing and not simply reacting to a problem. I did not make this move to recall product - I came to prevent human illness.

These changes will require the bar for plants to be raised, but I am confident that the industry will meet this challenge. I believe our resources need to be focused on those areas of most concern.

This will allow FSIS to better focus its inspection efforts on the product, processes, and establishments most likely to pose a public health risk.

Closing

As I said earlier, we know from past experience that we can improve food safety and protect public health by relying on sound science, and working with industry, consumers and employees to more effectively mitigate risk.

We also know that we cannot move forward unless all of our food safety partners are communicating, cooperating and collaborating with us to make an enhanced risk-based inspection system a reality.

But there are still a lot of unknowns, and that is why your work here today and tomorrow on critical questions concerning risk-based systems is so important.

In particular, I want you to describe the ideal working group that you feel can best assist FSIS and the Office of Food Safety, in approaching the next steps needed to enhance our risk-based system through an open and inclusive process.

How many people should serve on this committee? Who needs to be represented? Would this be a subcommittee of NACMPI or perhaps something different? If it is different, who would chair, and how often should the working group meet? We need your recommendations.

But remember my challenge as you address these and other questions that are before you today. Push the food safety envelope. We need advice and recommendations that are not routine. Ideas that are based on creatively applied science.

Do not focus on what has worked in the past for us. Focus instead on what will work in the future for every stakeholder in this important process.

This is a crucial test, but one I am confident we will pass. We have to begin work on enhancing our risk-based systems so that we can meet the food safety challenges of the next 100 years. The state of public health is constantly evolving, and we cannot afford the risk of not evolving along with it.

In 1900, out of the top ten causes of death, nine were infectious diseases. They included enteritis, dysentery, cholera and typhoid. Now over 100 years later, the top 10 diseases are largely those that we have brought upon ourselves.

I bring this point up because it illustrates why I am here today asking you for your advice, comments, and input on how best to enhance our risk-based system. Remember I took this job to save lives.

I want to thank you again for your time this week and I look forward to reviewing the committee's final report.