Presentations
FSIS Approach to Production Food Safety -
Presented by John Ragan, DVM, National Livestock Leader, Animal Production Food Safety
Staff, Food Safety and Inspection Service, U. S. Department of Agriculture,
Discover Conference, June 1998, Nashville, Indiana
Very few well-informed people would dispute the fact that animal-based foods in the
United States have been among the highest quality and safest in the world for many years.
This has been made possible in large part by our generally healthy herds and flocks and by
an excellent aggregate of food inspection and regulatory systems. While this pleasant
picture has remained very much the same, the background has changed dramatically in recent
years. The E. coli O157:H7 outbreaks in the early l990s and a series of other
food-borne disease incidents, along with the traditional American media hype, have
resulted in numerous vocal advocacy groups and a general public which increasingly demand
a higher standard of food safety. These heightened expectations apply particularly to meat
and poultry products. As a result of these expectations, recognition of the limitations of
traditional inspection methods, and the availability of improved science-based options,
the Food Safety and Inspection Service (FSIS) has made a dramatic change in the meat
safety system. The development and adoption of the Pathogen Reduction-Hazard Analysis, and
Critical Control Point Rule (HACCP) was a long process, and involved major input from all
of the numerous stakeholders impacted by such a major change. The HACCP Final Rule,
published July 25, 1996, in essence established that the safety of meat and poultry foods
is the responsibility of the industry that produces food products, and that the
governments role is to oversee the industrys safety process, and to insure
that it is adequate in content and application. Thus, the farm-to-table strategy for food
safety was institutionalized. An excerpt from the background statement of the HACCP Final
Rule (p.38810) aptly describes the posture of FSIS and indeed the opinion of a large part
of the American public: "Those in control of each segment of the farm-to-table
continuum bear responsibility for identifying and preventing or reducing food safety
hazards that are under their operational control." The Animal Production Food
Safety Staff (APFSS) of FSIS has the charge to address food safety problems at the level
of production, transportation, and marketing of live animals destined for slaughter and
processing. Our primary basis may be found in the HACCP Rule as published on July 25,
1996. In particular, Section 417.2 of that rule requires that slaughter plants
"determine the food safety hazards reasonably likely to occur
before, during,
and after entry into the establishment." The required HACCP plans must address
significant chemical, physical, and microbiological hazards, including those associated
with live animals entering the plant. As you are aware, FSIS has no regulatory authority
over management of live animals prior to arrival at a regulated establishment. Also the
Agency is not seeking such authority. We therefore seek to contribute to food safety in
animal production by education, information, and collaboration with other governmental,
industry, and public entities with concerns or responsibility for the safety of
animal-based food. We feel that this voluntary approach has the best chance of enhancing
food safety in the long run. We believe also that food safety production practices are
often cost-effective for the producer. Adequate response to the production food safety
challenge will require:
- Determination of what is required by industry HACCP plans as the basis for risk
identification and management in live animals,
- Definition of these requirements in practical, cost-effective management practices which
producers may use to maintain and expand markets,
- Support of and assistance in focusing research on areas where answers to food- safe
practices are not available,
- Development in all segments of the food animal and support industries of an awareness
that HACCP-compatible production practices are needed,
- Assistance in moving information regarding food-safe management practices from the
research arena to multipliers of all types and ultimately to all of the production
industry players, and
- Encouragement of producer adoption of Best Management Practices (BMPs).
We feel the best approach to creating this response is through working within FSIS to
define food safety needs, and with all animal industry and veterinary medical stakeholders
to address those needs. Food animal producer organizations at the national level have
established a solid foundation for producing safe food through existing Quality Assurance
Programs (QAPs). We propose to work with all parties involved to encourage increased food
safety content in those programs, and their adoption by all producers. Perhaps the best
way to describe our approach to animal production food safety is to review the APFS
activity in the last year or so. FY 97We funded, by the competitive contract
process, four major risk and cost-benefit analysis pilot projects:
- ARS received $300,000 to add to their broiler national epidemiological and risk
reduction survey using industry farms to study Salmonella and Campylobacter.
Dr. Sterns group will identify important sources of these organisms and evaluate
competitive exclusion and other interventions for their ultimate impact on levels of
carcass contamination.
- Colorado State University received $245,000 and will evaluate the impact of certain good
hygienic management practices on the level of carcass pathogens in lambs at five major
slaughter plants.
- Iowa State, the Food Safety Consortium and North Carolina State Universities received
$272,244 to compare pathogen contamination antemortem and postmortem from all-in-all-out
and continuous flow swine production systems.
- The University of Illinois, the Food Animal Production Consortium and Cornell University
were awarded $299,144 to assess a culled cow identification system in studying cattle from
the farm, through markets, and at slaughter. They will seek to determine the effect of
production practices on the prevalence of Salmonellae in culled cows.
Educational contracts were awarded to the:
- Livestock Conservation Institute for a survey of current educational programs for food
animal producers. An additional year of the Food Safety Digest was also funded;
- Dairy Quality Assurance Center for development of biosecurity training materials and
their evaluation;
- DG Management Consultants of California for development of bilingual educational videos,
an internet web site, workbooks and educational analysis of teaching methods for poultry
producers in partnership with the California Poultry Egg and Meat Quality Assurance
Programs.
- Tuskegee University in partnership with Texas A & M and the Research Triangle
Institute of North Carolina for surveying small farm and ranch producers to identify
educational needs in food safety and quality assurance;
- Alabama State Department of Agricultures Veterinary Office to bring together small
packers and producers to discuss the importance of HACCP; and
- Missouris Department of Agricultures Veterinary Office to reach small
producers to educate them about HACCPs implementation and the importance of Quality
Assurance Programs.
FY 98While resources were severely limited this year we were able to identify
approximately $500,000 to support animal production food safety education and information
activity in the field. Producer Food Safety and Quality Assurance Programs are one of the
most promising and important activities addressing food safety concerns on the farm. FSIS
has committed to a long-term strategy of enhancing State partnerships to build on the
progress already made in a number of states. Before the end of the year we hope to have
project support in place in 10-12 states. Our approach to this effort has been to partner
with FDA to add production food safety support funds to their existing residue reduction
contracts. This means that for this year, only states with residue-reduction contracts are
available for consideration. We hope, however that our resources and delivery mechanisms
will both be expanded significantly for next year. For those states involved this year we
will be supporting the development or enhancement of local partnerships to serve as
information and communication vehicles for food animal producers. The key State partners
are:
- State veterinarians and State Department of Agriculture officials
- Local federal agency representatives of USDA and HHS
- Universities and Extension Service
- Veterinarians in practice
- State public health officials
- Markets, dealers and transporters of livestock, poultry and eggs
FSIS will provide to state partners and other users available information on HACCP and
compatible production practices. We will also update information as research results
become available. One priority concern is that small producers have the information at
hand to respond to demands created by HACCP implementation. Some of the basic
HACCP-compatible production practices are:
- Animal or premise identification
- Quality Assurance Program certification
- Good Production Practices which reduce disease
- Proper, documented use of biologics, antibiotics, and other drugs
- Good general sanitation which can potentially reduce pathogen load
In addition to the support of state partnerships described above, we hope
to have two other cooperative projects under way before years end. One would be
collaboration with the Animal and Plant Health Inspection Service (APHIS) to fund a state
educational-informational project similar to those already discussed. The other is a joint
venture with the Cooperative State Research, Education, and Extension Service (CSREES) and
a major university to develop a training program in auditing good production practices
which are included in industry Quality Assurance Programs. This educational program could
be beneficial to both government employed veterinarians and private practitioners to
develop skills as verifiers of processes. FY 99If our funding remains intact through
the budget process, we will expand our support of state level food safety partnerships to
include twenty-five or thirty states during the year. We should also have resources to
support targeted pilot studies and programs to fill in some of the information blanks in
the pathogen reduction safety portion of production food safety. A review is currently
under way among all involved federal agencies to determine if the current program of
surveillance and response for antibiotic and other chemical residues is the best possible
in the HACCP era. Should needs for adjustments in the residue program be identified,
recommendations will be made and extensive public input will be encouraged. We believe
that state animal health and public health officials can be key leaders in bringing
together all of the existing players for information and producer support in enhancing
food safety at the level of production and marketing of food animals. We have observed a
number of states where these local partnerships are already up and running. We hope to
help get out the word of their efforts and successes, and encourage others to develop
similar projects appropriate to their local industry and needs. In this way important food
safety and quality assurance information can be made available to all producers and a
vital link forged in the farm to table food safety chain.
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