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Food Safety and Inspection
Service United States Department of Agriculture Washington, D.C. 20250-3700 |
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Food Safety and Inspection
Service United States Department of Agriculture Washington, D.C. 20250-3700 |
Remarks prepared for delivery by Thomas J. Billy, Administrator, Food Safety and Inspection Service, via satellite from Geneva, Switzerland, before the public meeting on HACCP-based Meat and Poultry Inspection Concepts, June 24, 1997, Arlington, VA.
It's a pleasure to welcome you today to this public meeting on HACCP-based Meat and Poultry Inspection Concepts. Although I am not able to be there in person, there are a number of points I want to make before you begin these important discussions.
The issue at hand--how we can change inspection to better use our finite resources to improve food safety, while still assuring current consumer protections-- is of utmost importance. It is a critical element in our strategy for change that has been ongoing for almost three years.
We have made much progress in that strategy so far. We are in the process of implementing the final rule on Pathogen Reduction and HACCP, which sets new requirements for plants that slaughter and process meat and poultry. We are developing a strategy to improve the safety of egg products, which will include mandatory HACCP. We are laying the groundwork to rely more on quantitative risk assessments to determine how to allocate our resources according to public health risk. Outside of plants, we have taken tangible steps to improve food safety at points along the farm-to-table chain. And we are implementing a major reorganization so we are better equipped to operate in a HACCP-based system.
Although we have made significant progress, we have still not addressed a fundamental weakness in our traditional inspection program for meat and poultry. The large majority of our resources are devoted to operating an inspection program that may not provide us with a good enough return in terms of food safety and other consumer protections. We owe it to the public to explore whether new models for in-plant slaughter inspection can be developed that provide the same level of protection, but allow some inspection resources to be reallocated to food safety tasks off-line in slaughter plants and to new food safety tasks in processing plants and during the distribution of meat and poultry products once they leave the plant.
Our resource-intensive, on-line activities are keeping us from carrying out other tasks that could have a substantial effect on food safety. For example, transportation and storage after products leave the inspected plant are vital links in the farm-to-table food safety continuum. But right now, we exercise our jurisdiction over products outside inspected establishments to a very limited degree. It is time that we systematically place a greater inspection focus on conditions and practices during distribution that may contribute to the growth of pathogens. In short, we need to determine if we can reallocate some of our resources so that the public gets the best possible return from its investment in food safety.
We have known for some time of the need for this type of inspection reform. Studies conducted over the past decade by the National Academy of Sciences, the General Accounting Office, and by FSIS itself have established the need for fundamental adjustments. One recommendation, in particular, said in a nutshell what our goal must be. The NAS recommended that we shift from our total reliance on Federal organoleptic inspection to prevention-oriented inspection systems, based on risk assessment.
With implementation of HACCP on the horizon, the shift to industry-based, prevention-oriented food safety systems will be in place. And our current and future risk assessment activities will better enable us to quantify the risks that are posed by products and processes and allow both industry and USDA to better target our efforts.
However, the organoleptic, carcass-by-carcass inspection that goes on day in and day out in slaughter plants across the Nation, has not substantially changed since 1906, when the Federal Meat and Poultry Inspection Act was passed. The inspection procedures we currently use are based on a time when animal diseases were rampant and, thus, focus disproportionately on this area. And they do not mesh with our new regulatory approach, which recognizes that industry is accountable for meeting food safety performance standards and for determining how best to meet those standards.
With HACCP soon to be in place, it is time to reassess two areas. First, we must reassess the relative allocation of resources by industry and USDA to non-food safety, on-line activities to prevent diseases or otherwise unwholesome carcasses from being used.
Second, we must reassess the relative allocation of FSIS and State resources between non-food safety and food safety tasks. The process we are beginning here today will determine the appropriate and acceptable degree of reallocation.
In case there is any misunderstanding, however, let me be very clear. This project is not about abdicating the role of the government inspector. On the contrary. We see a strong need for government presence to verify that all of the requirements related to food safety and other consumer protections are met. The public must have confidence that FSIS is carrying out its regulatory responsibility. We know that, and we intend to make sure that any new system maintains and strengthens that confidence.
This project is about the nature of that government presence. Does it make sense that 45 percent of the entire inspector field force is stationed at fixed positions along production lines in slaughter establishments to address essentially non-food safety tasks, while other farm-to-table food safety tasks go unaddressed?
Does it make sense that 72 percent of our in-plant inspection force is assigned to only 21 percent of the plants requiring Federal inspection? And that this leaves in-distribution roles presently ignored?
These questions are particularly important at this time, considering the new food safety tasks FSIS inspectors will need to perform to oversee industry activities associated with the Pathogen Reduction and HACCP rule. We must redirect some inspection staff capacity within plants to carry out these important oversight functions. And we must reallocate some inspection resources from slaughter to HACCP-related inspection tasks in processing plants.
The fact is, inspectors will become more important, not less important, in the FSIS of the future, and we are taking a number of steps to strengthen our inspection workforce.
First, our long-term objective is to upgrade inspection positions to reflect the increasing complexity of their jobs, and so far we have begun this process with 100 positions.
Second, we are increasing the number of compliance officers by 108 over the next year. This reflects the importance of strong enforcement in maintaining food safety, both in-plant and during distribution.
Third, we have begun a continuing education program to prepare our inspectors for their future regulatory roles. Inspectors will have the opportunity to enhance their scientific backgrounds through courses in such areas as microbiology, risk assessment, and environmental sanitation.
The result will be an inspection workforce that is better equipped to assume its proper role of verifying that industry is meeting all food safety and consumer protection requirements.
This strong government presence is important not only domestically but internationally. Our citizens must have confidence that the products they eat are safe whether they are produced in the United States or abroad. Before we permit meat and poultry products to be imported into the United States, a foreign country must demonstrate the equivalency of its inspection program.
I can assure you that a strong government inspection presence in slaughter and processing plants will continue to weigh heavily when we evaluate foreign countries to determine if their inspection systems are equivalent to ours. We will not have a system where one standard is set for domestic products and another for imported products. They must both be equivalent.
In closing, we must determine how we can best use the resources we have to protect the public health, while continuing to ensure other important consumer protections. We are committed to maintaining a strong food safety program in the United States and to demanding the same of foreign countries exporting to the United States.
We look forward to your participation in the development of new inspection models in a HACCP environment.
For Further Information Contact:
FSIS Food Safety Education and Communications Staff
Public Outreach and Communications
Phone: (202) 720-9352
Fax: (202) 720-9063
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