Presentations
Overview of the U. S. Department of Agriculture's
Farm-to-Table Food Safety Strategies -
Presented by Bonnie Buntain, D.V.M., M.S.,
Director (former), Animal Production Food
Safety Staff, Food Safety and Inspection Service, USDA
It is an honor to be invited to speak at and participate in this important conference
covering animal and public health perspectives of our animal-based food supply. I thank
the organizers of the American Academy of Veterinary Pharmacology and Therapeutics, the
American Veterinary Medical Association, FDA-CVM and the University of Maryland Regional
College of Veterinary Medicine for bringing together a stimulating spectrum of experts in
this forum.
I congratulate all of you at this conference on recognizing two very important points.
First, that all of us---government, industry, academia, veterinary and human medical
professionals, and the general public all share responsibility for food safety and
decreasing risks of microbial resistance. And second, we must always keep a farm-to-table
focus when seeking solutions to preventing public health problems. It will require
multiple efforts all along the farm-to-table continuum for true progress to occur.
USDA's comprehensive approach to food safety recognizes the shared responsibility of all
of us involved in producing, preparing and regulating food. It is not helpful to point
fingers and assign blame to certain segments of the farm-to-table continuum for food
safety problems. While I recognize that much pressure in being placed on animal producers
and veterinarians to improve food safety, we all share in the responsibility for food
safety and public health. We must all determine what we can do, individually, to ensure
the farm-to-table food safety chain is strong.
I would like to review the USDA Food Safety and Inspection Service's (FSIS) initiatives in
our farm-to-table food safety strategies, and where we are headed.
Animal Production and HACCP-Compatible Practices
The farm-to-table chain begins at the animal production level. While we use the term
farm-to-table, we by no means see FSIS directly intervening on the farm or in the animal
markets. The animal production area from the farm and during intermediate stages before
the animals are slaughtered is an example of where voluntary and not regulatory approaches
work best. At the animal production level, FSIS encourages research, applied studies and
educational activities to enhance adoption of food safety practices. FSIS is primarily
working with information multipliers toward the voluntary application of food safety
assurance programs applying the highest industry standards. We believe that food safety
and quality assurance programs need to apply the latest science and Hazard Analysis and
Critical Control Point (HACCP) concepts of prevention, especially with the use of
antibiotics, pesticides and other veterinary medicinal drugs.
Because new USDA meat and poultry regulations clarifies industry's responsibility for food
safety, slaughtering plants will consider the potential public health risks with incoming
animals when developing their preventive plans. With HACCP systems, slaughtering plants
must address substantial chemical, physical and microbial hazards associated with animals
entering their plants. Plants have many options when considering incoming animals. They
could reject animals they assess to be significant risks for violative residues and/or
pathogens, sort animals or groups of animals based on risk, conduct additional testing,
review producer records, demand quality assurance certification or letters of guarantee
from suppliers, or they may have their own safety and quality specifications for
management practices. Plants will need to verify their HACCP plan is working with whatever
option they choose for controlling significant hazards carried in or on incoming animals.
FSIS believes HACCP-compatible practices include producer record keeping, good hygiene,
herd health management, residue avoidance and, where appropriate, pathogen reduction
strategies. By HACCP-compatible, I mean those good production practices which would
provide slaughter plants the assurances they need from their suppliers for food safety.
These practices are important for marketing animals to plants with HACCP systems and for
international and branded markets. Quality assurance programs already embody
HACCP-compatible practices such as record keeping, residue avoidance, animal or group
identification, good herd health management and biosecurity, veterinary consultation, and
pathogen reduction guidelines in broiler, egg and turkey good management practices. We
believe these quality assurance practices are HACCP-compatible practices. This means when
producers follow their quality assurance program, they will be able to provide slaughter
plants the information and assurances needed for the in-plant pathogen reduction and HACCP
systems plans. These practices are the same ones needed for assurances for specific
retailers, niche and international markets.
We have a steep learning curve when it comes to finding ways to reduce pathogens during
animal production. This is why animal production food safety research is highlighted in
the President's Food Safety Initiative, as Under Secretary for Food Safety explained on
Monday. We recognize reducing pathogens in animals is a significant challenge. Scientific
information is lacking to demonstrate what is routinely effective and economically
feasible at the production stages to reliably eliminate or at least substantially reduce
pathogens on carcasses. There are many complicating factors controlling microbial hazards
before slaughter, including unknown reservoirs, the ubiquitous nature of some pathogens,
the lack of specific, sensitive and inexpensive diagnostic tests, and the lack of an array
of cost-effective, preventive interventions such as vaccines, microbial exclusion
products, and other technologies. However, until science proves otherwise, we should
accept this basic hygienic premise: good herd and flock health will help reduce pathogens.
We must develop plans based on the best information we have today and update them as new
scientific information becomes available.
FSIS is guiding basic research by outlining research priorities to our sister federal
agencies and the research communities. Currently, the White House has requested the Office
of Science and Technology to address farm-to-table food safety research priorities. Under
secretary of Food Safety Woteki represents FSIS on this research priorities committee, and
I'm confident results from this conference will be considered in their deliberations.
Last year FSIS supported four pathogen reduction applied studies focusing on practical
production situations. We currently have contracts for risk factor analysis projects in
lamb, broiler, non-fed cattle and pork production. The objective of these contracts is to
collect data on the most likely animal production risk factors and practical
interventions. The animals will be studied through the slaughter process to see if
microbial contamination can be decreased. Some of the risk factors being studied are
transportation distance, time held in lairage before slaughter, mixing of animal groups
and dirty hides. We should have preliminary results by the end of this year.
FSIS is also committed to supporting educational initiatives that promote the adoption of
food safety and quality assurance programs. Our goal is to assist the animal production
community in implementing voluntary programs based on science and HACCP concepts. We
believe some States may need additional support to coordinate farm-to-table food safety
efforts. Last year, we funded seven contracts to promote producer education in food
safety. These educational contracts were awarded to the Dairy Quality Assurance Center,
the Missouri Department of Agriculture, the Alabama Department of Agriculture and
Industries, the Livestock Conservation Institute (two contracts), DG Management
Consultants (for Salmonella enteritidis in eggs), and Tuskegee University. FSIS
also provided additional funds for the Food Animal Residue Avoidance Databank (FARAD) to
enhance its work in minor species and ratites.
Today we are seeing some States take action on food safety at the animal production level
by forming food safety partnerships from farm-to-table. Some State Departments of
Agriculture, such as California and Missouri, have taken a leadership role by working with
producers, Universities and the Extension Service, public and animal health officials, and
practicing veterinarians to implement voluntary commodity educational and certification
systems which address food safety and quality. We believe industry-driven, grass-roots
approaches are the best way to achieve our mutual end goals of a safe food supply and a
vibrant agricultural economy. The role of the federal government, and FSIS, as I mentioned
earlier, is to step out of the way as much as possible while remaining present to provide
support and guidance to industry-driven and local initiatives. However, because there is
so much change occurring in food safety with new meat and poultry establishment
regulations and new challenges on the international and public health scenes, it is
imperative adaptive changes begin now to prevent possible future regulatory burdens.
In-Plant Pathogen Reduction and HACCP Rule Implementation
In contrast to the voluntary educational approach FSIS utilizes at the animal production
level, USDA has a direct regulatory responsibility at the slaughter and processing plants.
On July 25, 1996, USDA reached a milestone in its farm-to-table strategy with publication
of the final rule on Pathogen Reduction and Hazard Analysis and Critical Control Point
Systems (HACCP). Next week approximately 300 of the largest meat and poultry slaughtering
and processing plants will be required to have developed and implemented an HACCP program
with controls to prevent and reduce food safety chemical, physical and microbial hazards.
Small plants will have until January 2000 to do the same. We are encouraging industry to
implement HACCP programs before they become mandatory. FSIS is providing opportunities for
small plants to participate in demonstration pilot projects to learn more about how HACCP
systems can be applied to small plants.
FSIS has set pathogen reduction performance standards for Salmonella to verify
HACCP systems are effective in reducing contamination with pathogenic microorganisms. All
plants that produce raw ground meat and poultry must meet these levels or be below them.
Except for the zero tolerance for E. coli 0157:H7, in raw ground beef, which has
been in effect for several years, these are the first microbial performance standards for
pathogens ever required for raw meat and poultry.
The Agency's inspection force will review each plant's HACCP plan and become familiar with
the plant's pathogen reduction and HACCP systems and plans. Inspectors will verify that
plants monitoring, verification and corrective actions are being conducted according to
their own HACCP plan. Inspectors will review records, observe practices throughout the
system and take on-site tests. FSIS has a new Technical Service Center in Omaha, Nebraska.
It will operate the HACCP Hotline beginning this week to provide uniform information to
FSIS employees and industry. The toll-free number is 1-800-233-3935, or via the Internet
(HACCP.Hotline@usda.gov).
In addition to the HACCP systems and Salmonella performance standards, since
January 1997, all meat and poultry plants have been required to develop and maintain
written Standard Operating Procedures for Sanitation. These good manufacturing practices
are the foundation for HACCP systems. They are required to reduce the likelihood of
harmful bacteria contaminating the finished products. All slaughter plants have also been
required to test for generic E. coli as an indicator of how well they are
controlling fecal contamination.
FSIS's strategy in plants is to encourage the development and use of new technology to
reduce pathogens. Steam pasteurization and antimicrobial rinses are examples of new
technologies encouraged as a means to improve food safety. As you know, the Food and Drug
Administration (FDA) has recently approved the use of irradiation as a means of pathogen
control for fresh and frozen red meats, which includes beef, lamb and pork. FSIS is
working closely with FDA to finish a USDA rule defining procedures required of plants to
irradiate meat, including ground beef. FSIS views irradiation as another weapon in the
fight against pathogens.
These are all significant and historic changes within plants and the Agency. FSIS intends
to make additional changes in the way it carries out inspection activities. We know some
activities FSIS performs in plants have limited public health protection value. We also
know there are important public health tasks we do not currently perform under our system
of inspection. The Agency believes a redesigned inspection process within plants will
enable FSIS to redeploy part of its current workforce to the product transportation and
storage areas. These areas would greatly benefit from more regulatory oversight. There are
also new inspection HACCP verification tasks in both slaughter and processing plants. FSIS
has recently selected three pilot plants to explore new ways of conducting inspection.
With a finite workforce and a Federal budget process highly focussed on balancing it,
redeployment may be our only option. There will be a public process to critique the pilot
project findings and hopefully pave the way to better use of inspection resources for
public health protection.
Food Product Transportation and Storage
Transportation and storage are important links in the food safety chain. The FSIS, FDA and
State and local governments share authority for oversight of food products at this stage.
FSIS and FDA are working to develop standards governing the safety of foods during
distribution. FSIS is placing emphasis on time and temperature control as a means of
minimizing pathogen growth. Good manufacturing practices, new technologies for temperature
control and record keeping are all important considerations to prevent temperature abuse.
Individuals responsible for transporting food products may not be aware of practices which
contaminate food during shipping. Educational initiatives will be needed if we are to be
successful. This is an area which will receive much more attention once our new inspection
system is implemented.
Retail Food Safety
At the retail level, FSIS is working with FDA and State officials to ensure the adoption
at the State level of food safety standards based on HACCP. State and local authorities
have primary responsibility for food safety oversight of retail stores and restaurants.
FSIS and FDA help provide guidance to foster the development and adoption of sound food
safety standards and practices nationwide. One way we are doing this is by participating
in the development of the Food Code with the Conference on Food Protection. The Food
Code is a reference guide for retail outlets and institutions on how to prepare food
to prevent foodborne illness through good sanitation, proper cooling and cooking
temperatures, and HACCP concepts of prevention. States and local jurisdictions have the
option of adopting these standards and enforcing them. Everyone in this audience should
encourage their State to adopt and enforce the Food Code. This would be a positive
step in farm-to-table food safety. Another initiative FSIS supports in the retail area is
conducting a series of training sessions for State regulators in cooperation with the
Association of Food and Drug Officials. These nationally televised sessions provide
information on new food safety technologies and packaging systems at the retail level.
Consumer Education
One of our most important farm-to-table food safety initiatives is consumer education. In
June, USDA, FDA and the Centers for Disease Control and Prevention (CDC) sponsored a
conference on changing food safety behaviors. In October, a partnership of industry,
professional and consumer protection groups, educational organizations, and State, local
and federal government agencies announced the FIGHT BAC! KEEP FOOD SAFE FROM BACTERIA
campaign. This campaign will be gathering momentum in the coming months in the media and
in schools. The BAC is a green, slime-oozing bacterium cartoon symbol. The message is
simple to remember:
1. CLEAN: Wash hands and surfaces often
2. SEPARATE: Don't cross-contaminate
3. COOK: Cook to proper temperature
4. CHILL: Refrigerate promptly
And of course there are all types of public information materials and a web site
(www.fightbac.org).
FSIS has extensive consumer educational services. One of the most successful has been the
Meat and Poultry Hotline (1-800-535-4555). The Hotline provides accurate, up-to-date
information to callers on safe food handling and the prevention of food borne illness.
Home economists, registered dietitians and food technologists staff this public health
service. To receive more public service education materials, contact our consumer
education staff at 202-690-0351.
My challenge to this audience is to consider if a partnership for food safety education
could embrace farm-to-table initiatives. As historic changes occur in food safety, it is
important to address behavioral changes through education from the farm, through marketing
of animals, food transportation and storage, food service as well as consumers. At the
animal production level, a partnership for education may have significant benefit for food
safety as well as ensure the viability of producers large and small.
FoodNet
The changes FSIS is making to strengthen food safety from farm-to-table will benefit us
all. From a public health perspective, we expect a safer meat and poultry supply to
translate into fewer cases of food borne illness. The USDA has set a goal of reducing food
borne illnesses by 25 percent in five years. We will be able to measure our progress
through the expanding FoodNet active surveillance system. The FoodNet is a cooperative
project among FSIS, FDA, CDC and State public health offices. It will track the incidence
of food borne illness cases as they occur and apply modern technology, such as microbial
epidemiology, to understand the causes of illness and sources of pathogens.
Research and Risk Assessment
Research is extremely important to the success of food safety initiatives and policies.
The regulatory changes FSIS has made are based on the best scientific information
available. However, we recognize USDA and industry must have new information to improve
the effectiveness of food safety programs.
FSIS is not a research agency. USDA's Agriculture Research Service is charged with
conducting animal and plant-based research for USDA agencies. For that reason, FSIS
developed in 1996 a Food Safety Research Agenda as one means of communicating its
priorities. For human health research, FSIS is working with the CDC, National Institutes
of Health, Department of Defense and the FDA for research planning and implementation. A
challenge for the future will be to integrate all of the research needs stated in the FSIS
Research Agenda and the President's Food Safety Initiative. To assist in the process, the
President's Food Safety Initiative call for the convening of an interagency working group
by the White House Office of Science and Technology Policy to coordinate Federal research
priorities and planning. The goal of this working group will be to develop a coordinated
research plan, which will extend to research partners in States, industry and academia.
This committee is now being formed and Dr. Woteki is representing USDA.
Risk assessments are vitally important to USDA's ability to determine the public health
hazards associated with pathogens. It can be used not only to target research needs, but
to identify interventions consistent with the public health risk. Risk assessment can help
evaluate alternative strategies and the most cost-effective solutions. Because risk
assessment is a relatively new science, we need investment at the ground level. USDA's
Agriculture Research Service is doing a considerable amount of computer modeling for risk
assessments. The FDA is investing in a new center with the University of Maryland to focus
on risk assessment. FSIS scientists have designed a risk assessment model for hamburger
and E. coli 0157:H7, and are working with FDA and others on a quantitative risk
assessment for shell eggs and egg products. FSIS has also decided to contract for a risk
assessment on Bovine Spongiform Encephalopathy in cooperation with USDA's Animal and Plant
Health Inspection Service and a university. The risk assessment will allow us to determine
whether there is any scientific justification for taking regulatory action regarding the
consumption of certain tissues where the hazard is more likely to be present.
International Trade
FSIS is committed to the development of harmonizing international food safety standards.
FSIS is working through the Codex Alimentarius Commission, which is the most appropriate
venue to bring science, risk assessment, and equivalency to the foreground. We recently
established a new Codex policy committee designed to increase U.S. government
representation in policy issues. Under secretary for Food Safety, Dr. Woteki, chairs this
committee with the State Department, Foreign Agriculture Service and the U.S. trade
representative's office. Its purpose is to improve science and technology policy
discussions.
The recent World Trade Organization appeal panel's decision on hormone -treated beef is
historic. The panel decided there is no justification for a nine-year-old European ban on
beef treated with any of the six forms of growth promoting hormones. The U.S. successfully
argued the ban was not risk-based. The European Union now is also charging the U.S.
residue program is not equivalent. FSIS is currently operating a statistically valid
national monitoring and surveillance residue program. We are developing new strategies for
residue control in an HACCP inspection environment. Our focus on residue control must be
based on risk assessment and public health. Industry must bear the responsibility to
prevent adulterated product with government oversight. The question of how to address
public health risks and international confidence in our residue safe food supply will be
debated in public forums this year. Mr. Gary Stefan, Deputy Director of the FSIS Animal
Production Food Safety Staff, is leading the Agency's residue program of the future
development team.
As we pursue various international trade issues, our farm-to-table food safety strategies
will place us in a strong negotiating position. Our public health protection efforts will
put us in a better position to market meat and poultry products overseas. Our domestic
food safety programs are science-based and consistent with international trade
obligations, allowing us to expand global markets.
Summary
In closing, FSIS believes the farm-to-table food safety strategy we have developed and are
implementing will protect the public's health and agriculture's future. FSIS is working
with all levels of government, industry, academia, professional organizations, researchers
and consumer protection groups to improve food safety at each point in the farm-to-table
continuum. By working together with you, we will help achieve reasonable goals of ensuring
a safe and wholesome food supply, reducing foodborne illness in the U.S., and expanding
global export markets. This can only be accomplished if each part of the farm-to-table
food chain shares responsibility for ensuring food safety and adopting practices which
prevent and reduce foodborne illness. Through cooperative efforts we will preserve and
hopefully expand our safe, affordable and wholesome food supply for the world.
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