The Impact of Pathogen Reduction/HACCP on Food Animal
- Informational material distributed to FSIS District Offices on APFS issues.
Today, I will:
- Provide key information on the new USDA's rule and its regulations thats important
for producers and veterinarians to be aware of;
- Describe in-plant residue controls, which consider options for incoming animals;
- Provide some insight on how implementation of the rule may impact food animal producers;
- Help you understand why producer Quality Assurance Programs are HACCP-compatible and are
important for marketing to plants with HACCP systems.
As you know, there have been many reports of deaths and illnesses due to these and other
foodborne illnesses. Almost everyday the media is covering news stories about these
organisms. The publics concerns about the safety of the food supply have been
heightened. Public Health Agencies have raised concerns that more adequate controls form
farm to table are needed.
USDAs Food Safety and Inspection Service recognized it needed to modernize its
90-year-old system. A critical gap in the inspection program was that it did not
adequately prevent or control harmful pathogens on raw meat and poultry. Changes in
FSIS total approach to food safety were needed. HACCP is accepted nationally and
internationally as a science-based, preventive risk reduction system.
On July 25, 1996, after much public input, the final rule was published. The rule
- Industrys role is to produce safe meat and poultry products.
- FSIS role is also to set appropriate food safety standards, to make sure those
standards are being met through regulatory oversight, and to take enforcement action when
these standards are not met.
According to the rule:
- As of January 27, 1997, plants are required to have SOPs in place to address sanitation
- Each plant must describe all procedures it conducts daily, before and during operations
- Plants are responsible for detecting, documenting and correcting sanitation deficiencies
- Inspectors will continue to look for and require the correction of problems
- FSIS will verify SOPs are maintained and effective, and take appropriate action if a
plant fails to comply with SOP requirements
Since January 1997, plants have also been required to test carcasses for generic E.
coli as an indicator of the adequacy of the plants ability to control fecal
- FSIS has adopted performance criteria for E. coli. FSIS is using the term
"criteria" because they are guidelines, not regulatory standards.
- The original baseline surveys and performance criteria published in the final rule were
based on the excision method of removing meat from carcasses for testing.
- FSIS is not conducting new baseline surveys using a nondestructive sponge sampling
technique for swine, cattle, and turkeys.
- Plants must evaluate their own results using statistical process control.
- FSIS will make available interim criteria for use in evaluating sponge samples until
final criteria can be set.
Meat and poultry slaughter and processing plants must implement HACCP systems to prevent
hazards in meat and poultry products:
- Chemical (illegal drug, antibiotic, pesticide and other) residues
- Physical hazards (metal, needles,
- Microbial pathogens
USDA will set performance standards for Salmonella contamination levels on raw meat and
poultry, and plants must meet or be below these levels. The rule makes it clear that
slaughter and processing plants are responsible for food safety and must assume more
practical responsibility for control of these hazards in their produces. The rule also
makes it clear that those in control of each segment of the food industry must bear the
responsibility for identifying and preventing or reducing food safety hazards. Although
FSIS has regulatory authority primarily in the meat, poultry, and egg processing plants,
it has the responsibility to work with all parts of the food production and marketing
chain to help ensure we are all doing our best to improve food safety.
FSIS promotes voluntary adoption of producer quality assurance programs. FSIS is working
with FDA to address safe transportation of products. Through the Food Code, FSIS works
with local and State authorities to improve wholesale, retail and food service food safety
practices. FSIS has helped develop the FIGHT BAC! Consumer education campaign. Provides
extensive consumer information and Hotline services.
We often are asked "What about imports?"
- We are currently working with our trading partners to ensure their systems are
equivalent to our HACCP rule.
- Our State meat and poultry inspection programs must be "equal to" the federal
Plants were required, on January 27, 1997, to:
- Implement SSOPs
- Begin generic E. coli testing for fecal contamination
- Begin preparations, including education themselves, about how they are going to develop
PR/HACCP plans. FSIS provided extensive guidance to plants to facilitate implementation.
Plants will need to implement HACCP systems and meet Salmonella performance standards
in a phased-in manner according to their size.
- Large establishments - 500 or more employees
- Small establishments - 10 or more but fewer than 500 employees
- Very small establishments - Fewer than 10 employees or annual sales of less that $2.5
In terms of percentage of animals whose products end up in interstate or
internationally shipped meat and poultry products:
- This year, about 75-80% of all animals are being marketed to plants implementing HACCP;
- When the small plants come on-board, about 90%; and
- Starting the year 2000, every animal will be marketed to plants with HACCP systems.
FSIS does not have, and does not seek, regulatory authority over live animals from the
farm to the slaughterhouse gate, and the rule does not have regulatory requirement to test
live animals for hazards. The rule clearly describes our role as promoting voluntary
producer efforts to implement food safety preventive practices. The potential impact on
animals marketed to HACCP plants is found in Part 417.2. This section of the
does require plants to evaluate hazards from live animals.
Part 417.2 states the plants must conduct a hazard analysis "to determine the food
safety hazards reasonably likely to occur before, during and after entry into the
establishment. The key words for you are "reasonably likely to occur" and
The rule also describes what hazards must be considered in a hazard analysis. All of them,
except food additives and food decomposition, can apply to incoming animals.
Although the focus and the biggest challenge for plants is meeting microbial performance
standards, plants are responsible for preventing illegal, or violative, residues from
adulterating their meat and poultry products. Therefore, plants are responsible for
- They must evaluate significant residue hazards of incoming animals;
- Develop a HACCP plan for controlling residues; and
- Determine information needed to help develop the residue control plan.
When considering how to control residues, plants have many options. They can:
- Reject animals with a high risk of violative residues;
- Develop specifications for high-risk classes of animals for residue violations.
- Buy only for suppliers on a QAP. As of January 1999, Hormel will only purchase pigs from
producers certified on the Pork quality Assurance Level 3 program.
- refuse to purchase from suppliers with past residue violations that caused adulteration
- require written assurances or letters of guarantee of no adulteration; or
- ask for sufficient history of production practices to determine whether or not
significant residue hazards are likely. Plants need to use residue tests appropriate for
the treatment history of the animals slaughtered.
Plants can also:
- periodically test animals or carcasses for residues; and
- convince suppliers of the importance of preventing violative residues, plants could
periodically visit suppliers or obtain independent third party verification that good
production practices are being implemented
There are sufficient historical data that show these classes of animals are more likely
to have violative residues than others. It is imperative proper withdrawal times prior to
slaughter are observed. These are the primary classes of animals on which both plants and
FSIS will need to focus residue testing efforts to protect the publics health. With
the advent of HACCP systems, packers may need more information on incoming animals to
develop their HACCP plan and prevent residue adulteration of their products.
Practices which will provide packers with the information and assurances they need are
called "HACCP-compatible." Industry standards for good production practices
exist for various commodities and include:
- Being a certified producer on a QAP
- Identifying treated animals and enabling packers to know the source of animals
Other HACCP-compatible practices are:
- Keeping herd health and treatment records, which could supply purchasers with
information and improves management.
- Another process which may become more important for branded and international markets
will be having a third party verify your food production practices by auditing your
By now, I hope you see how important the practices embodied in the QAPS are.
Being a certified producer will not only promote excellence in animal health and welfare,
but will also ensure safety of meats by ensuring proper drug and antibiotic use.
Certified producers are more likely to have the proper records which assure purchasers of
good production practices.
It has been shown that when producers follow QAPs, they have fewer residue violations,
especially repeat violations. Following the good production practices also potentially
reduces contamination with pathogens through good hygiene and animal health. Quality
assurance also increases production efficiency and animal quality.
National and international marketing systems are moving toward branded products with
quality and safety assurances from suppliers along the chain. Verified programs that have
been audited by a third party, such as an accredited veterinarian or other trained expert,
may provide added value to purchasers because of the additional assurances and
documentation of certain practices being followed.
The Dairy QAP has taken a HACCP-like approach to looking at specific food safety control
points for residue avoidance.
- Ten control points are clearly described.
- Although the QAP focuses on residue avoidance in mil,, critical control points for
preventing residues in beef are stressed.
- Producers who follow the practices in the Milk and Dairy Beef QAP will be able to
provide slaughter plants the assurances needed for their residue control plans for culled
cows and bob veal calves.
Although the Milk & Dairy QAP certification is primarily an educational process for
residue food safety and milk quality, the practices of record-keeping, animal
identification, maintaining good herd health and hygiene, educating all on handling drugs
properly, and working with a veterinarian are keys to success when marketing culled cows
and bob veal calves to slaughter plants implementing HACCP systems.
Plants will have more trust when buying culled cows and bob veal calves from producers
with QA programs. Recently, this Program has also incorporated Best Management Practices
for Biosecurity to control infectious diseases and hopefully reduce risk of foodborne
pathogens by good sanitation and herd health management.
The Level 3 PQA contains industry standards for good production practices. It requires
producers to go to educational meeting and recertify every two years with a veterinarian
or swine expert. According to a recent article in the National Hog Farmer, up to now, pork
packers have borne the brunt of the responsibility for food safety. Starting in January
1999, Hormel will buy only from producers certified on the Level 3 QAP. This will provide
them with added assurances that producers are educated about industry standards.
The Beef QAP is often tailored by States. In the Northeast, there has been a focus on
culled dairy cattle and how best to work with dairy producers to avoid violative residues
in beef. The BQA stresses total quality management practices for improved beef quality and
We have talked a lot about residue avoidance, but what about foodborne pathogens?
Although plants will be testing for generic E. coli and some will be checking for
pathogens, there are no requirements to test live animals or to traceback to the farm.
Some integrated poultry plants are working closely with their suppliers on ways to
practically reduce contamination of birds with Salmonella and Campylobacter.
Research is needed to know what will reliably reduce pathogens in live animals and
Plants may also be interested in knowing if animals someday can be sorted based on their
risk of carrying pathogens. Plants could process high-risk animals at the end of the day
or make other decisions based on food safety. Much research is needed to determine if
sorting of animals pre-slaughter could consistently reduce contamination of carcasses.
To look at the possibility of sorting culled dairy cattle prior to slaughter, FSIS
and the Food Animal Production Medicine Consortium conducted a pilot survey of over 5,000
cows at slaughter across the country during both winter and summer seasons. The
hypothesis was that cows in poor body condition would shed Salmonella more than cows in
good body condition. We could not prove this. The shedding of Salmonella at slaughter is
much more complex that body condition. Another survey is on-going looking at livestock
markets and transportation distances.
In summary, I have discussed:
- the new PR/HACCP Systems rule for meat and poultry plants and the farm-to-table concepts
for food safety;
- the options plants have for addressing residue control and incoming animals;
- the potential effect this rule may have on food animal producers; and
- the importance of being on Quality Assurance Programs. These programs all are
HACCP-compatible; in other words, they are the types of practices plants need for reducing
risks of chemical, physical and microbial hazards in the animals they purchase.
Producers are being affected because the new rule covers physical, chemical and
microbial hazard control in meat and poultry slaughter plants. An example is that Hormel
and most large pork packers now require suppliers to be on the Pork Level 3 QAP and have
their certification card. However, plants have many options on how to address these
hazards when considering the live animals supplied to them. Packers may need more
information on the animal supplied. The information can best be supplied by producers who:
- are on QAPs and are certified;
- have animal or premise identification systems place; and
- keep good treatment and disease records which improves productivity, herd health, and
- helps prevent food safety problems.
As we address consumer concerns about food safety, meet the demands of the HACCP era,
and seek international markets, those producers who follow industry standards for good
production practices, and who are certified on a QAP, will best be able to turn these
challenges into opportunities. Working together, we will build consumer confidence in the
safety of our food supply from farm to table.
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