This page provides a text alternative
for the March 2008 issue available in full-color
How You Can Prevent Recalls
By Jeff Tarrant, LCDR U.S. Public Health Service
It is Friday night. Hermann Q. Fuerschlinger, jovial and beloved owner of Fuerschlinger's Better Meat
Company (fictitious name and company), is preparing to take his family out to dinner. The phone rings.
He picks up the receiver and wishes the caller a good evening, but his good mood quickly dissolves.
The speaker introduces herself as a representative of USDA's Food Safety and Inspection Service
(FSIS). She informs him that the ground beef samples collected earlier in the week were found to be
presumptively positive. Confirmatory test results are expected tomorrow morning. Mr. Fuerschlinger
can't believe it. He asks, "Are you sure?"
She replies, "Yes. As a matter of fact, our folks need to meet with you as soon as possible to
get product and distribution information so we are ready for your recall."
Mr. Fuerschlinger drops the phone into the cradle, hunger pangs rapidly being displaced by a sour stomach.
Could this happen to you? Or, more importantly, can you prevent it? In many cases, the answer is, "Yes."
Pathogens—Test and Hold
Products sampled for microbiological testing may be either shipped or held pending the results.
Shipping your product before the test results come back is perfectly legal, but it's not necessarily
cost effective if there is a chance the test will be positive for a pathogen. Holding your product may be
difficult, especially if the product has a short shelf life and storage space is at a premium.
Furthermore, the vast majority of tests (over 12,000 tests for E. coli O157:H7 in 2006)
do come back negative. However, the short- and long-term costs to your business of even one recall can be enormous.
In 2006, 10 of that year's 34 recalls (29 percent) could have been avoided if the companies had held their
products until testing was complete. Therefore, although "test and hold" is strictly voluntary,
FSIS urges establishments to hold product until testing results arrive.
Allergens—Intensify Quality Control
An increasing number of recalls are due to undeclared allergens. FSIS refers to these as "ingredients of
public health concern" because to some consumers with food allergies, exposure to even very small
amount can be fatal. Milk, eggs, fish, crustacean shellfish, peanuts, tree nuts, wheat and soybeans
are the most common "ingredients of public health concern," accounting for over 90 percent of
all reported food allergies in the United States.
It's essential that products declare these ingredients on the label if they are in the food. If they are
not declared then the product is mislabeled, and product already shipped will need to be recalled.
How can you prevent a food recall due to undeclared allergens? According to Lisa Volk, director of
FSIS Office of Field Operations, Recall Management Staff, "more double-checking of label and ingredient
statements and better quality control could go a long way."
In many companies today, changing ingredient suppliers and multiple product lines can make their food
production process complicated and make it a challenge to ensure all ingredients are absolutely controlled.
The responsibility to ensure that the food label accurately reflects the product rests with the company.
FSIS recommends that operators double-check to ensure that product formulations match the ingredient statements.
This is particularly important when suppliers of ingredients are changed. A seemingly insignificant change in
the vendor or ingredient specifications may result in the unintended introduction of an allergen and, potentially,
By holding tested product pending the test results, and by double-checking that your ingredient statement is
accurate and that there are no undeclared allergens-perhaps even making it a critical control point-you can
avoid costly recalls, helping to protect public health and your bottom line simultaneously.
In the next edition of Small Plant News, we'll discuss what to do, if despite your efforts at preventing
it, you are obliged to recall a product. For more information on food recalls, visit FSIS' Web site at
www.fsis.usda.gov/Fsis_Recalls/index.asp or call the Recall
Management Division at (202) 690-6388.
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Protect Your Suppliers and Distributors
By Keith Payne
Ensuring the safety of the food supply from intentional contamination is not just your responsibility as a
plant owner or operator, but one that needs to be shared by all who handle food from production to the
instant it is served on a plate. The amount of time, effort and pride you pour into your products can all
be erased by one act of deliberate contamination before supplies reach your plant, or after your finished
products leave your premises. As a small business, you can ill afford to have any product tampering associated
with your brand, even if the deliberate contamination didn't occur within your plant.
That's why FSIS has developed the Guide to Developing a Food Defense Plan for Warehouse and Distribution Centers.
Even though the agency is targeting the owners and operators of warehouse and distribution centers with
the distribution of these resource tools, the next time you speak to your suppliers or distributors,
you might want to bring up the topic of food defense and make sure they have a copy of this guidance
document. And if you have a warehouse, put the guidance to use for your own operations as well.
In the December 2007 and January 2008
issues of Small Plant News, you learned about the importance of a food defense plan and reducing the
insider threat. FSIS' new guide integrates these concepts to assist owners and operators in developing
cost-effective food defense plans for warehouses and distribution centers.
However, the agency didn't craft the guide on its own. "We developed this guide in consultation with a
variety of warehouse and distribution center establishments," said Suzanne Rigby, executive associate of
FSIS' Office of Food Defense and Emergency Response. "We wanted
to make sure the information presented within the guidance document serves our target audience well by being
beneficial, practical and achievable."
Three steps within the guide help owners and operators of warehouse and
distribution centers take measures to safeguard their operations from intentional harm. Outlined broadly,
these steps are:
- Conduct a Self-Assessment
- Develop a Food Defense Plan
- Implement Your Food Defense Plan
By using this guide, owners and operators can develop a food defense plan that is specific to their facility.
"We want folks to keep in mind that not all of the guidance contained in this document may be
appropriate or practical for every warehouse and distribution center," added Rigby. "As a
small plant owner, we recommend you work with your suppliers and distributors; review the guidance and
assess which preventive measures are suitable for their operations."
So, take some time and share this material with your partners in the food chain. The Guide to Developing a
Food Defense Plan for Warehouse and Distribution Centers is available on FSIS' Web site at:
Guidance_Document_Warehouses.pdf (PDF Only).
If you or others need help or have questions about this guidance, call FSIS' Office of Food Defense and
Emergency Response at (866) 395-9701.
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Food Safety Resources
By Mary Gioglio
Today, more than ever, businesses must take steps to protect their products from intentional contamination
and chemical, biological or nuclear threats. As we mentioned in the December 2007
and January 2008 issues of Small Plant News,
one way to safeguard your business is to develop a Food Defense Plan and FSIS has the resources to help.
Food Defense: Security in a Foodservice Operation (DVD) was developed by the South Dakota State
University Cooperative Extension Service in partnership with FSIS. While the title implies it is for
foodservice businesses, the information contained in the DVD can apply to any business. Assessing risks to
your business, developing contingency plans, communicating the plans with your employees and putting those
plans into action are all covered. In addition to the DVD, FSIS has published many guidebooks for developing
food defense plans in meat and poultry plants, including Developing a Food Defense Plan for Meat and Poultry
Slaughter and Processing Plants (booklet).
These resources and others are available on FSIS' Web site at www.fsis.usda.gov or you can order copies from
FSIS' Food Safety Resources Brochure for Small and Very Small Plants. A PDF of this brochure is found at
and the order form can be faxed to (202) 690-6519. There is also an online version of the brochure,
where requests can be submitted electronically to www.fsis.usda.gov/Science/
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By Sheila Johnson
The National Advisory Committee on Meat and Poultry Inspection (NACMPI)
meeting was held on February 5-6. The Committee meets biannually to discuss food safety issues and make
recommendations to the Secretary of Agriculture. At this particular meeting, the NACMPI discussed FSIS' planned
public health-based slaughter inspection system for young chickens and how a similar approach could be used for
inspection in processing and other slaughter establishments. Transcripts, presentations and the committee's
recommendations are available on FSIS' Web site at www.fsis.usda.gov/News_&_Events/
(Past Events). Call (202) 690-6520 for further assistance in obtaining these materials.
Methods to Ensure Effective Sanitation
Continuing its efforts to improve outreach to small and very small plants, FSIS is sponsoring a monthly
seminar series covering a variety of technical topics concerning agency policies and new technologies
of interest to industry. These seminars are offered to all participants at no cost and conducted via NetMeeting,
which uses Internet access for viewing the presentation and a phone line for the audio portion. On April 16, 2008,
a seminar titled Methods to Ensure Effective Sanitation in Meat, Poultry and Egg Products Establishments
will be led by Robert Savage of the HACCP Consulting Group. This seminar will emphasize methods that small and
very small meat, poultry and egg products plants can implement to ensure effective sanitation and thus safer
products for consumers. To register for this seminar, call (800) 336-3747.
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Compliance Guidance Issued for Small Plants
By Karlease Kelly
FSIS has issued compliance guidance on a range of regulatory issues for small and very small plants through
various resource documents. These guidance documents do not set regulatory requirements. However, they provide
information to plant owners and operators on how they can meet regulatory requirements to ensure food safety.
One of the most recently issued documents is the Compliance Guideline for Controlling
Salmonella in Poultry (PDF Only). This resource describes concerns and validated controls for each
step in the broiler slaughter process. It targets small and very small poultry plants to help them better comply
with regulatory requirements.
Another recently issued resource is the Compliance Guideline for Small and Very Small Plants Appealing
Inspection Decisions (PDF Only). In this document, FSIS provides information to help plant owners and managers
understand the appeals process and, in turn, learn how to make an appeal regarding an inspection decision.
For a complete listing of these compliance guidelines, visit
Also, for upcoming net meetings where subject matter experts review the compliance guidance and answer questions
online or by phone, visit www.fsis.usda.gov/News_&_Events/
For assistance in obtaining any of this information, call (202) 690-6520.
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Handling Food Animals with Care
By Maxine Hillary and Carol Romeo
While preventing intentional and unintentional contamination of the meat, poultry and processed egg products
supply remains FSIS' primary mission, the agency is also committed to ensuring the humane handling and slaughter
of food animals. There are different schools of thought on the welfare of animals that are raised and
slaughtered for food, but Federal regulators, members of the meat and poultry industry, consumers and animal
welfare groups agree on the importance of the issue and pursuant to Federal law, FSIS routinely takes steps
to ensure that its workforce, as well as industry, is ensuring humane handling and slaughter.
Agency veterinarians enforce humane handling and slaughter regulations pursuant to the Humane Methods of
Slaughter Act. The oversight begins at the moment a live animal reaches your facility. FSIS veterinarians and
slaughter line inspectors observe the methods by which livestock are slaughtered, and they are obligated to
take appropriate enforcement actions.
FSIS Veterinarian Thomas McDougal who works out of the Dallas Field Office comments on the part of his job
that requires him to enforce the Humane Slaughter Act. "Ensuring that livestock are handled and
slaughtered in a humane manner is a vital and very satisfying role that I carry out as an FSIS Public
Health Veterinarian. We have been given the legal mandate and the necessary authority to enforce the
humane handling and slaughter of livestock and it is something that I take very seriously, and I
think it is one that the consuming public takes very seriously as well."
His perspective is echoed by Janet Riley, senior vice president for public affairs at the
American Meat Institute in Washington, DC. Riley considers that the best practices come from within
and regardless of motive, result in a better product. "Ensuring optimal welfare is good for
livestock—and good for business. Good handling reduces livestock stress and increases meat quality,"
For some producers, humane handling not only satisfies a legal statute and guarantees brand loyalty
from the consumer—it's the right thing to do. Tedd Heilmann, general manager of Organic Valley,
a cooperative of organic farmers based in LaFarge, WI, considers it a moral issue. The people who buy
his product insist that the animal be treated humanely at all points of processing.
"We believe deeply in humane animal treatment. We want to ensure these animals' well-being up to
the point of the most humane slaughter possible and work with our processors to make sure that the holding
areas and the holding pens that the animals are in prior to the slaughter meet our standards. All of our
farmers have a strong sense of compassion and conviction about humane animal treatment," says Heilmann.
Humane slaughter practices are effective in the processing of most food animals, even those that are
not covered by the Humane Methods of Slaughter Act. Although there is no specific Federal humane handling
and slaughter statute for poultry, poultry regulations under the Poultry Products Inspection Act
require that live poultry must be handled in a manner that is consistent with good commercial practices,
which means they must be treated humanely. Recommendations are described in a September 2005 FSIS Notice -
Treatment of Live Poultry Before Slaughter, which is accessible at
www.fsis.usda.gov/OPPDE/rdad/FRPubs/04-037N.htm. The Notice is based on information provided in the National Chicken Council (NCC) Animal Welfare Guidelines.
FSIS recommends that you periodically review the following steps to ensure humane handling of all
food animals. First, you should assess your current systems for any handling problems. Next, take steps to
minimize these problems. Finally, periodically evaluate whether your systems are working.
FSIS is committed to working with you and other stakeholders to improve the treatment of livestock and
poultry. Although the agency does not have authority under the law to regulate how animals are raised on
farms—before they reach a slaughter facility—you are encouraged to develop and use sound
standards for the care, handling, transportation, and slaughter of livestock.
FSIS believes that industry and others who have an interest in animal welfare and safe food production
should continue to work proactively to ensure humane handling of animals and to produce even safer food.
In the next month's issue of Small Plant News, we'll cover the various organizations you can turn to
for more information on humane handling.
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Small Plant NEWS
Editor: Keith Payne
Production: Jeff Tarrant, LCDR, U.S. Public Health Service
Design: Rowena M. Becknel
Contact: Small Plant News, USDA/FSIS, Aerospace Building,
3rd Floor-Room 405, 14th and Independence Ave., SW, Washington,
DC 20250. (202) 690-6520