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BSE – A Challenge That Brings All Partners in the Farm-to-Table Chain Closer Together
An Overview of FSIS’ Measures to Protect the Food Supply

Remarks prepared for delivery by Dr. Garry McKee, Administrator, Food Safety and Inspection Service, before the National Cattlemen’s Beef Association’s BSE Issues Forum, NCBA’s Annual Convention, January 29, 2004, Phoenix, Arizona.

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Introduction

slide 1, cover(Slide 1) Good morning everyone. I truly appreciate the National Cattlemen’s Beef Association’s (NCBA) invitation to participate in this very important forum. For over a month, the Bovine Spongiform Encephalopathy (BSE) issue has been “front and center” with us as everyone has concerns about public health, food safety, and their livelihoods.

However, on the brighter side, the American public remains confident in the U.S. meat supply – and for good reason. With organizations such as the NCBA taking a leadership role in tackling the BSE issue and protecting the livestock industry, consumer confidence has not wavered. I’m especially pleased that NCBA modified this annual convention to address BSE and provide these interactive forums.

FSIS’ Measures to Increase Consumer Confidence

(Slides 2, 3, 4, 5)Government also has played a major role for maintaining high consumer confidence. FSIS has implemented a number of sound, science-based measures over the past couple of years that has driven down Salmonella, Listeria, and E. coli O157:H7 prevalence rates in meat and poultry products. In addition, the number of meat and poultry product recalls in 2003 decreased significantly from 2002. And, of course, FSIS and its sister agencies moved effectively and forcefully upon the discovery of a BSE case in this country, further strengthening already formidable BSE preventive measures.

slide 2, Salmonella declining Slide 3, Listeria declining Slide 4, E. coli O157:H7 declining Slide 5, fewer recalls

Apply the “Gold Standard” Everywhere

Slide 6, HACCP as the gold standard(Slide 6) When it comes to our inspection system, we apply the “gold standard” to further improve food safety and public health – the Hazard Analysis and Critical Control Points system, or HACCP. When I came on board at FSIS, I made it very clear to everyone – within FSIS and the establishments that we regulate – that we will all be held accountable for knowing and operating effectively under HACCP. It is simply in all of our best interests. Consumers benefit; government fulfills its responsibility to the fullest; industry profits from producing the highest quality product; and above all, public health improves. It’s what I call a “common sense” approach to improving public health.

Slide 7, apply the gold standard everywhere along the chain(Slide 7) But to improve public health, it goes even further than applying our “gold standard” to slaughter and food processing establishments.” It is critical that every segment of the farm-to-table chain be held accountable for providing the safest product possible to the next segment of the chain. The principles of HACCP are the standard accepted throughout the world…a standard that we know works. HACCP is the most scientifically advanced process for food safety worldwide. Food safety is too important to be left to guess work or luck; HACCP gives us the assurance that potential hazards are controlled and eliminated from the food production cycle. I urge you to examine your own operations for improvements that can be made and points where the HACCP system can be employed.

Working with Producers to Develop Best Practices

Slide 8, best practice for animal production(Slide 8) This is why FSIS is working with livestock producers, researchers and other parties to develop a list of best management practices for animal production facilities, such as feedlots, to provide guidance in reducing pathogen loads before slaughter. As many of you know, last September we held a symposium to discuss ways to significantly reduce the levels of E. coli O157:H7 in live animals before slaughter.

The dialogue that was generated from that meeting was very beneficial toward our development of guidelines outlining best management practices at the pre-harvest stage, which we expect to publish this year. Once these guidelines are developed, you can expect to see an aggressive, grass roots outreach effort by FSIS to distribute these to producers and any other interested parties.

This is just one way in which we are fulfilling our public health duty. Although we don’t have jurisdiction over producers, transporters, retail establishments, and consumers, we work with all these segments to ensure they have the most current information and “know how” in order to produce the safest products possible.

Greater Cooperation, Communication and Control

Slide 9, Overcoming the BSE challenge will close the gap between all links.(Slide 9) Working together is not only critical for lowering microbial contamination, but it is essential when it comes to the BSE challenge. I believe this issue will further close the “gap” between all the links of the farm-to-table chain. This is absolutely what we need to improve public health – greater cooperation, communication, and control over the safety and wholesomeness of meat products. To this end, FSIS has been working closely with APHIS, FDA, state governments, industry and consumers to ensure our BSE prevention and response measures are fully effective in the United States.

I’d like to focus the rest of my discussion on what FSIS is doing to protect the beef supply against BSE. I know that many of you are fully aware of these recent rules, but I want to review them at this time to provide a springboard for our discussion later in this forum.

Ban on Non-Ambulatory Disabled Cattle

USDA's BSE Policies(Slide 10) First, as you know, on December 30, 2003, Secretary Veneman announced a ban on all non-ambulatory disabled cattle from entering the human food supply. We define non-ambulatory disabled cattle as cattle that cannot rise from a recumbent position or cannot walk. They are also cattle that have broken appendages, severed tendons or ligaments, nerve paralysis, fractured vertebral column or metabolic conditions.

FSIS’ Veterinary Medical Officers, or VMOs, are responsible for enforcing this ban, and we provided them clear details on when, and if, cattle are to be condemned at the slaughterhouse. For instance, in the case where an animal has passed the VMO’s ante-mortem inspection at the slaughter establishment and then suffers an acute injury, such as falling and breaking a leg, on its way to the knock box, the VMO will verify that the animal suffered such an acute injury and allow it to be slaughtered. However, in cases where a VMO cannot determine that a specific, acute injury occurred that caused the animal to become non-ambulatory disabled, then the VMO will condemn that animal and prevent it from entering the slaughter establishment.

VMOs will also continue to condemn all cattle that are showing central nervous system symptoms, even if the animal is ambulatory. The VMO will contact the Animal and Plant Health Inspection Service (APHIS) Area Veterinarian-in-Charge to allow APHIS the opportunity to collect BSE surveillance samples.

Product Holding

Slide 11, Test and Hold Notice(Slide 11) Following the Secretary’s immediate ban on all non-ambulatory disabled cattle, FSIS issued four new regulations to further enhance safeguards to prevent BSE from entering the food supply. These actions add an additional level of protection to an existing strong food safety system.

The first policy is actually a notice, which announces that our inspectors are no longer marking cattle tested for BSE as “inspected and passed” until confirmation is received that the cattle have, in fact, tested negative for BSE. We are referring to this as the “test and hold” policy.

Specified Risk Material

Slide 12, SRM Rule(Slide 12) The second policy is an interim final rule on specified risk material. We declared that skull, brain, trigeminal ganglia, eyes, vertebral column, spinal cord and dorsal root ganglia of cattle 30 months of age or older and the small intestine of all cattle are specified risk materials and that these are prohibited from entering the human food supply. Tonsils from all cattle are already considered inedible and therefore do not enter the food supply. These enhancements are consistent with the actions taken by Canada after the discovery of BSE there in May.

Slide 13, SRM Guidance(Slide 13) To help determine the age of cattle before they are slaughtered, we issued two forms of guidance to our VMOs. When an animal is presented for slaughter, the VMOs need to first examine documentation such as birth records, cattle passports, or some other form of age and identification verification. If the VMOs find there are significant reasons for questioning the validity of these records, or there are no records, then they are to verify the age of the cattle through dental examinations.

Slide 14, Dentition of cattle(Slide 14) When they (VMOs) examine an animal’s teeth and see that at least one of the second set of permanent incisors has erupted, then he/she will consider that animal to be 30 months of age and older. We recognize that permanent incisors of cattle erupt from 24 through 30 months of age, but to be most protective of public health, we will err on the side of caution and go with this prescribed dentition procedure.

Advanced Meat Recovery

Slide 15, AMR Rule(Slide 15) The third policy is an interim final rule on advanced meat recovery (AMR). FSIS had previously established and enforced regulations that prohibit spinal cord from being included in products labeled as “meat.” This rule expanded that prohibition to include dorsal root ganglia, clusters of nerve cells connected to the spinal cord along the vertebral column, in addition to spinal cord tissue. Also, because the vertebral column and skull in cattle 30 months and older will be considered inedible, we will not allow them to be used for AMR.

Slide 16, BSE workshops(Slide 16) In our efforts to help the owners and operators of small and very small establishments that process cattle or produce products using AMR, we are holding a series of teaching workshops from January through March 2004. The workshops are designed for small and very small establishments, State plants and State program personnel. We want to ensure that all processors receive and understand this new regulation. This outreach effort is a prime example of how we reach out and educate partners along the farm-to-table chain to ensure that the safest food reaches American tables.

These workshops are being held in Tacoma, Washington; Boise, Idaho; Sioux Falls, South Dakota; Madison, Wisconsin and Binghamton, New York on the following dates you see here on the screen. We hold them on Saturdays to meet the needs of many small business owners because we realize that it is very difficult for them to take time off or close production during the week.

Banning Air-Injection Stunning

Slide 17, Air-injection Stunning Rule(Slide 17) Finally, the fourth policy is an interim final rule to ban the practice of air-injection stunning. This was done to ensure that portions of the brain are not dislocated into the tissues of the carcass as a consequence of humanely stunning cattle during the slaughter process. While the use of this type of stunning device is not common, officially banning its use not only ensures that it will be prohibited domestically, but will also make it a requirement for equivalency in foreign establishments.

Communication

All four of these regulations became effective on January 12, 1004. There is a comment period for each of the final interim rules, and if you have questions or comments that come up after today’s forum, then I would encourage you to submit your written comments to FSIS’ Docket Clerk by April 12, 2004 (the deadline).

Slide 18, Constituent Update(Slide 18) You can also follow the latest Agency policies on BSE and other factors affecting food safety through FSIS’ Constituent Update – a weekly newsletter that provides a wrap up of key agency information, notices, directives and upcoming meetings. If you are not currently receiving our Constituent Update newsletter, I urge to you sign up for it on our Web site. Of course, there is no cost, and there are absolutely no strings attached to signing up for this news service. This is one of many ways we communicate with all segments along the farm-to-table chain.

Closing

Slide 19, Sound science-based measures(Slide 19) These recent measures to further prevent BSE demonstrate how committed the Bush Administration and the Department of Agriculture are to protecting public health and improving our food safety system through sound science-based measures. These BSE measures are aggressive and advanced, and we are quite confident that they will they prevent BSE from getting into the U.S. food supply.

Slide 20, Closing(Slide 20) However, we can’t just rely on our measures alone. As I mentioned earlier, all parties need to take responsibility and work together to ensure that our food supply is the safest in the world. Quite often, difficult challenges make us stronger and more resolute in our determination to overcome them. I believe overcoming the BSE challenge will only bring us all closer, further improving an already robust and effective food safety system in the United States. This is vital to ensuring public health and will in turn ensure consumer confidence in U.S. beef products.

I appreciate your time here today and look forward to our interactive discussion.

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