Remarks prepared for delivery by Dr. Richard Raymond, USDA Under Secretary for Food Safety, at the Listeria Control Input and Planning Workshop, September 26, 2006, Denver, Colorado.
Note: Slides are available in an attached PDF document (500kb); individual
pages are linked within the text.
Good afternoon. I appreciate this opportunity to talk about
USDA's recent efforts to control and prevent foodborne illness
with an audience that has such a range of food safety experience.
Before I go any further, I would like to congratulate the dedicated
scientists who have been working to understand the transmission
of Listeria monocytogenes (Lm) through ready-to-eat
products from processing plant to consumer. This project complements
USDA's Lm risk assessment and control final rule to
help prevent listeriosis, which I will address today.
I noticed that three of the scientists on this project work
for Colorado State University, and two work for the University
of Nebraska. I'm happy to see that the Rams and the Huskers
are represented today because my son is a student at Colorado
State and my daughter attends Nebraska. [Comment on previous
Saturday's football games.]
100 Years of Meat Inspection
This year marks the 100th anniversary of the passage of the
Federal Meat Inspection Act, a watershed event in the history
of food safety and public health in the United States.
In 1906, only 163 establishments were federally inspected.
Today we inspect over 6,000. However, the scope of our activities
is not the only thing that has changed since then. Our approach
to food safety has evolved since 1906. We have taken on a much
more comprehensive farm-to-table view.
People 100 years ago could not have dreamed that scientists
would be studying a bacterium called Listeria. We have
made tremendous progress in the fight against foodborne illness,
but we still have a long way to go. That is why I take my job
Office of Food Safety
As the Under Secretary for Food Safety, I oversee the Food Safety
and Inspection Service, which carries out USDA's food safety
regulatory program, as well as public health outreach and education
activities focused on enhancing the safety of the U.S. food
Our mission is to ensure the safety and wholesomeness of the
nation's commercial supply of meat, poultry and egg products.
It doesn't matter if those products are imported to, or exported
from, the United States. Our efforts include protecting the
food supply from both unintentional and intentional acts of
My position also means that I head up the U.S. delegation to
the Codex Alimentarius Commission, the international body for
food safety standards.
FSIS has more than 10,000 employees, approximately 7,700 of
whom are inspection and veterinary personnel present daily in
nearly 6,000 meat, poultry and egg product processing plants
throughout the United States and its territories.
The products they inspect represent more than one-third of
all consumer spending on food in the United States and about
40 percent of all domestic food production.
One of my most important tasks is to ensure that every one of
our stakeholders plays a role in the creation and implementation
of sensible, effective science-based policies.
Today's workshop and the Food Safety Education Conference starting
tomorrow serve to as unique opportunities for government, academia,
industry and consumers to share ideas about the future of food
safety. We can do more together, cooperatively and collaboratively,
than we could ever think of doing alone.
A collaborative approach doesn't mean that you're going to agree
with every one of our policy decisions, but you'll be certain
that your voice is heard, and that your views are considered.
And it guarantees that consumers can be confident that the
products plants produce are the safest they can possibly be.
They will know that public health and the safety of the food
supply trumps all other issues when policies are made.
This approach is made possible by our reliance on the best
available science to strengthen our food safety systems. Good
science needs good data, and we are committed to both.
The Office of Food Safety remains dedicated to a collaborative
science-based approach because we know that it works.
Food Safety Successes
The best indicators of this success are those that directly
relate to pathogen reduction and public health outcomes.
The recent release of the 2005 data on the Incidence of Infection
with Pathogens Transmitted Commonly through Food by the Centers
for Disease Control and Prevention (CDC) clearly shows that
the reductions in human illness from foodborne pathogens witnessed
during the past few years have been dramatic.
Comparing human foodborne illness data from 2005 data with
1998 data, Listeria monocytogenes human illness rates
are down 32 percent.
In particular, our testing for Listeria monocytogenes
(Lm) in all ready-to-eat (RTE) products shows success
in pathogen reduction. Compared to a decade ago, we have made
substantial progress in Lm control.
Since 2000, the percentage of regulatory samples that tested
positive for Lm has fallen by 56 percent so that in
2005 only 0.64 percent of regulatory samples taken were positive
for this dangerous pathogen.
These numbers are a direct reflection of FSIS' science-based
policies implemented in the past 12 years.
Listeria Control Efforts
One of these science-based policies was to implement new ways
to detect and control Lm in RTE products.
USDA's 2003 interim final rule on control of Listeria monocytogenes
in ready-to-eat (RTE) meat and poultry products, based on a
thorough risk assessment, outlined three pathogen control strategies
that an establishment could choose from, depending on its product(s)
and the environment in which it operates. The first strategy
provides for a combination of a post-lethality treatment and
a growth-suppressing agent or process; the second strategy provides
for either a post-lethality treatment or a growth-suppressing
agent or process; and the third strategy relies on sanitation
as the primary mitigation.
Since implementation of the interim final rule, 57 percent
of establishments that were not already testing for Lm
have now begun testing, 27 percent have initiated the use of
an antimicrobial agent to inhibit the growth of this organism,
and 17 percent started using post-lethality treatments.
In January 2005, FSIS revised its Listeria monocytogenes
sampling verification procedures so that FSIS collects more
product samples at establishments that rely solely on sanitation
practices for Lm control, and collects fewer samples
in establishments that have more aggressive process control
measures and interventions. Thus, plants have an incentive to
do more to control Lm.
Even in the wake of disaster, FSIS was fully committed to improving
food safety. In response to Hurricane Katrina, FSIS implemented
new measures to control foodborne illness in the affected areas.
On September 20, 2005, FSIS began increased Salmonella
testing of raw meat and poultry products in the affected areas
of the Gulf Coast to provide microbial data to compare with
FSIS also trained additional non-field staff to assist in conducting
intensified verification tests in ready-to-eat establishments
for Listeria monocytogenes, including collecting food-contact
surface and environmental samples, to supplement product sampling
and food safety assessments. These provided an additional layer
of microbial testing and verification to ensure the safety of
the ready-to-eat meat products.
13 and 14)
The development and implementation of our Lm rule was
an important component of our existing risk-based inspection
system. However, FSIS must continue to develop the ability to
act proactively. That's why we are laying the foundation for
a more robust risk-based inspection system.
Our recent Salmonella initiative is also an important
step toward a more robust risk-based inspection system. Salmonella
is the number one cause of foodborne illness — 14.4/100,000
— 42,000 per year — reported only 500 deaths — all sources,
not just poultry.
According to our sampling data, the number of product samples
testing positive for Salmonella has been on the rise
in several poultry categories over the past few years, specifically
in young chicken (or broiler) carcasses — 16 %.
Our initiative to reduce Salmonella in meat and poultry
products incorporates 11 steps, including increased sampling
in plants where it's most needed and quarterly publication of
nationwide Salmonella data by product class. Carrot
The specifics of this important 11-step plan can be found on
FSIS' Web site at www.fsis.usda.gov.
Regardless of the type of foodborne pathogen we are fighting,
our risk-based approach will be driven by data. FSIS is working
to build a Public Health Data Infrastructure that will enable
us to collect the data we need, analyze that data, detect potential
problems, and redirect resources as necessary to protect public
health. In short, we need to get the right data to the right
people at the right time to make the right decisions.
We're after a common sense, cost-effective public health strategy
that best serves the American consumer and the meat and poultry
industry by preventing human illness.
To illustrate why we need to be more proactive, let me give
you an example of an inspector who inspects three plants.
Plant A produces a high-risk product, for example, ground poultry.
In addition, Plant A has a less than stellar food safety record
with a long list of Noncompliance Records, or NRs, many of them
very serious sanitation and hazard violations. It just had a
recent customer complaint and was warned that it's likely to
lose its grant of inspection unless it shapes up.
Plant B also produces ground poultry, but in this case, it's
spic-and-span. From the top management to the newest line employee,
everyone in this plant is dedicated to producing a safe product
and it shows. The plant has gone for years with very few NRs.
There have been no recalls or consumer complaints at this plant.
Now Plant C also has a record as spotless as the plant itself.
This plant produces canned hams, a product with lower inherent
So our inspector — we'll call her Anne — knows perfectly well
from years of consistent experience with all three plants that
every day B and C will pass inspections with flying colors.
She also knows that Plant B, even though its record is as good
as C, needs to be watched more closely because it produces a
higher risk product, ground poultry.
On top of that, Anne knows that Plant A, which also produces
ground poultry and has a bad inspection record, needs to be
watched extra closely.
But right now she can't do that. She is forced to spend approximately
the same amount of time and effort inspecting each plant, regardless
of the level of risk that these plants pose to public health.
So we're working to change that.
And of course, we're still going to go to each plant everyday.
And each inspector's work shift will probably still be around
eight hours long. But within that time, some plants will get
a closer look than others.
This would allow FSIS to direct its resources and attention
to those plants having difficulty meeting critical food safety
Currently, FSIS' efforts are focused on developing an objective
science-based measure that can meaningfully quantify how well
potential risks are being controlled in FSIS-inspected
processing establishments. We are also working on developing
a science-based measure for the inherent risk in a product.
We'll couple these two to develop an algorithm that will tell
us the risk for plant and product and allow us to concentrate
This measure is in the very early stages of its creation, so
we don't know how exactly it will affect individual plants yet.
However, we'll be sure to answer questions from stakeholders
before any final decisions are made.
That's not to imply that FSIS doesn't have its own ideas about
what should be measured and how. For example, we believe that
any enhanced measurement of establishment risk control should
differentiate between NRs that pose significant threats to food
safety and those that don't.
Our goal is to create a measure that uses objective data from
NRs, food safety assessments, microbiological testing, consumer
feedback and other sources that can make similar differentiations
to measure how well an establishment controls its inherent risk.
But the final product will be the result of input from employees,
consumer groups, industry, academia and all of our other food
safety stakeholders. I'm very serious when I say that everyone
needs a seat at the table.
That's why Resolve Inc., a neutral third party was selected
by FSIS, through a competitive bidding process, as recommended
by the National Advisory Committee for Meat and Poultry Inspection
(NACMPI). It will work in the coming months to gather and organize
the wide range of views concerning what needs to be included.
Resolve is currently conducting interviews to gather stakeholder
input. There is an upcoming NACMPI public meeting on October
10 and 11 in Washington, DC; and then this information will
be integrated into a cohesive risk-based policy.
I encourage your input during these meetings, as it will be
key to the development of a system that better protects public
I want to thank you again for inviting me here today. These
are important issues that need to be talked about. We have a
strong system in place, and that's due in large part to scientific
experiments and studies such as this Listeria project.
But we have to continue to improve and enhance our nation's
food safety system. This is something that we must accomplish
The state of public health is constantly evolving. We can't
afford to let ourselves, our partners, or our nation's food
safety systems stagnate. Standing still in public health is
really just a polite way of saying that we're moving backward.
The bottom line is that we all have the same objectives — safe
food and healthy people. We must never lose sight of these common