|Food Safety and Inspection
United States Department of Agriculture
Washington, D.C. 20250-3700
Remarks prepared for delivery by Dr. Catherine Woteki, Under Secretary for Food Safety, before the National Broiler Council, October 9, 1997, Washington, D.C.
It's a pleasure to be with you here today. As I was preparing for this presentation, I began to review in my mind some of the food safety problems we have encountered since I was sworn in as Under Secretary for Food Safety on August 5.
Of course, first on the list is the recall of more than 25 million pounds of ground beef prepared in a federally-inspected plant due to E. coli O157:H7. In addition to that recall, we have encountered several instances where ground beef contaminated with E. coli O157:H7 has been found at the retail level.
We also had a problem with dioxin, a chemical contaminant. Unusually high levels of dioxin found in two poultry samples from an EPA-FSIS survey led to an investigation that has just been completed.
Korea recently announced it had found E. coli O157:H7 in a sample of boxed beef exported from the United States. This is a potential food safety problem that is affecting trade between the two countries.
And just last Friday, we found a sample of dry, fermented sausage through our monitoring program that was positive for Listeria monocytogenes; fortunately, the product had not yet reached the retail level.
These examples illustrate the diversity of food safety problems that face us and will continue to face us in the future. And they illustrate a point I made earlier this month at a conference on E. coli held at Georgetown University. Our goal must not be to find a set of specific actions to address specific pathogens or other hazards. The challenge, for regulators, industry, and academia, is to develop a comprehensive approach that addresses all known pathogens and other hazards, and to be constantly vigilant to emerging ones. And this must be done in the context of the entire farm-to-table continuum.
As we respond to these individual food safety problems, we must not lose sight of this comprehensive approach. And that is what I would like to discuss today--the comprehensive approach I plan to take as Under Secretary for Food Safety.
I will talk first about HACCP implementation, because my top priority is to see HACCP implemented in a seamless fashion. We are closely approaching the first implementation date for HACCP, as you well know. On January 25, 1998, all large plants will be required to have HACCP in place, and they will be required to meet performance standards for Salmonella.
I believe the recent recall of ground beef illustrates how important good HACCP plans are to the production of safe products. I believe a good HACCP plan would identify the potential hazards involving the practice of recycling the previous day's production into the next day's production, and adding rework randomly into future production. A good HACCP plan would require greater focus on hazards associated with raw materials and steps to minimize those risks. And a good HACCP plan would provide consistent, reliable records.
We are confident that the large plants will be able to easily meet the demands of implementing the new HACCP system. We recognize that small and very small plants will have more difficulty in meeting their subsequent implementation dates, but we have a number of activities ongoing to assist them in developing their HACCP plans. I know you are already familiar with the generic HACCP models, the small plant demonstration projects, and the other assistance materials we have prepared.
Now that HACCP implementation is imminent, we are proceeding with two complementary initiatives. We are seeking new enforcement authorities, and we are testing HACCP-based inspection concepts.
Food Safety Enforcement Act of 1997
First, we need to tailor our enforcement approach to the new era. The Food Safety Enforcement Act of 1997 is our answer to that need. The bill would authorize the Secretary of Agriculture to:
Stop the distribution and order the recall of adulterated or misbranded meat and poultry in situations that pose a reasonable probability of a threat to public health.
Refuse or withdraw inspection based on any willful or repeated violation of Federal meat or poultry laws, and
Impose civil monetary penalties for violations of the meat and poultry laws.
Under HACCP, we are asking industry to take on more responsibility for controlling plant operations and keeping good records. Flexible enforcement--tailored to the new HACCP environment--is critical to the success of a HACCP-based system, and it is critical to maintaining consumer confidence in food safety. Certainly, we have strong enforcement tools now, but they lack the flexibility we need. Yes, we can withdraw inspectors, effectively shutting down a plant. But that's the atom bomb approach. Civil penalties can be imposed more promptly and can be tailored to the specific violations of the new food safety standards. The provision for civil penalties would provide us with an alternative to the very disruptive suspension of inspection to deal with serious problems that do not pose an immediate threat to public health and would provide an opportunity for plants to correct situations before they get out of hand.
The mandatory recall authority contained in the proposed law is really an insurance policy. We would continue to rely on companies' good will to recall adulterated product. But if they don't, it would enable us, in situations where there is a threat to public health, to recall product quickly in order to avoid adverse public health consequences. This is particularly necessary because epidemiological data is enabling us to quickly pinpoint potential public health problems and because of the increased complexity of our food distribution system.
The proposed legislation would also provide USDA with a withdrawal authority that is specifically designed for a HACCP-based system. With the authority to withdraw inspection for willful or repeated violations, we could deal with a plant's failure to assume its responsibility for designing and implementing systems that will ensure the production of safe and wholesome product. The current authority is concerned with specific performance problems, rather than with a failure to have adequate systems of control.
HACCP-Based Inspection Concepts
The second initiative we are undertaking now that HACCP implementation is imminent is the development of HACCP-based inspection concepts. We are exploring how we can change inspection to better use our finite resources to improve food safety, while still ensuring current consumer protections. Our resource-intensive, on-line activities in slaughter plants are keeping us from carrying out other tasks that could have a substantial beneficial effect on food safety. We need to devote inspection resources to new tasks under HACCP and to the distribution segment of the farm-to-table chain.
Last month, we consulted with the National Advisory Committee on Meat and Poultry Inspection, and the committee was very interested, and supportive, of this initiative. We have asked for volunteers to test new concepts, and in about one month, we will begin gathering baseline data in plants. There will be plenty of opportunity for everyone to provide input as we proceed with this project, and we will certainly keep you informed of our progress.
A second priority of mine, after HACCP implementation, is to ensure that regulatory decisions are based on science and that science guides food safety research. A major challenge for the future is having enough, and the right type of, information on which to base regulatory decisions and develop new prevention strategies. On a very basic level, we must encourage fundamental research on the natural history of human pathogens in animals. We need to know, for example, how these pathogens colonize livestock, how they are transmitted, and how they acquire the ability to produce toxins. This fundamental science will set the stage for potential breakthroughs in vaccines and other preventive approaches.
It's clear that scientific knowledge has not reached the point where we can say, with any certainty, what practices will reduce microbial pathogens in animals before slaughter. But we are seeing some progress. And epidemiological research to trace the problems we are having with E. coli O157:H7 and other pathogens back to their sources will be useful in our efforts to develop effective prevention strategies on the farm, in feedlots, and other intermediate stages before animals reach the slaughter plant.
We also need research to help us make regulatory decisions that are based on the most current science. HACCP provides an important framework for improving food safety within plants, but it must be combined with science-based performance standards that HACCP systems are designed to achieve. Through the HACCP rule, we have taken the first steps toward setting science-based performance standards for pathogens based on the levels of Salmonella currently found in various products. But our ultimate goal is to base performance standards on quantitative risk assessments. We need extensive, new data to conduct these risk assessments.
That is why we are extremely interested, and involved, in food safety research and development. As Under Secretary for Food Safety, I will ensure that regulators, consumers, producers, researchers and processors work closely together to identify research priorities.
My third priority is education throughout the farm-to-table chain. We need to educate those involved in producing, transporting, and preparing food, including consumers. The mind set on pathogen reduction may have changed, but not everyone is on board.
For instance, we need to do a better job of changing food safety behavior in the home. It's not enough to provide information--we must be able to change behavior. In June, USDA, in cooperation with FDA and CDC, sponsored a conference as a means to share information on changing food safety behaviors. We will soon announce a new education campaign for consumers that is the result of government and industry working together.
We also need to make sure all of you in industry are on board when it comes to taking responsibility for food safety within their own operations. Mandatory HACCP and performance standards for Salmonella provide an incentive for plants that slaughter and process meat and poultry to implement process control systems, but what about the rest of the industry not subject to this regulation? Producers of animals and other raw agricultural commodities do not always fully understand how their on-farm practices influence the safety of the food product ultimately reaching the consumer. Individuals responsible for the transportation of food are often not aware of practices that could result in contamination of food during shipment. Consumers, even in this day and age, and with all of the publicity on food safety issues, are often unaware that food choices and food handling practices could increase the risk of foodborne illness.
Market forces will have some influence at certain stages of the farm-to-table chain. For instance, we are already seeing retailers place pressure on their suppliers to have HACCP systems and to test products for contamination, and we believe such market forces will lead to change at all levels of the farm-to-table chain. But we also need to rely on education as a means of encouraging those involved in producing, transporting, and preparing food to follow good manufacturing practices.
Food safety as it relates to trade issues is another priority. With the trend toward HACCP, risk assessment, and pathogen reduction, we must address these issues on an international, as well as a domestic, level. While much of the media focus has been on how international trade is compromising food safety, I believe that the benefits of international trade actually provide an incentive to improve food safety.
As you know, the United States is heavily involved in the activities of the Codex Alimentarius Commission. I am pleased that we now have a U.S. Coordinator for Codex--Dr. Edward Scarbrough. He was previously the director of FDA's Office of Labeling and brings to this position an extensive background in compliance activities and an ongoing role in Codex activities.
The upcoming Codex Food Hygiene Meeting, to be held October 20-24, will provide an opportunity to talk about issues such as general guidelines for HACCP implementation and risk assessment procedures as a means of reaching international consensus on how to approach these food safety issues. These discussions provide us not only with an opportunity to ensure that imports to the United States meet high standards, but that U.S. products are competitive in world markets.
Equivalence is another issue that Codex is addressing, and it is an issue that the United States is grappling with as well. We are working with Canada, Australia, and New Zealand to develop criteria to use in making equivalence determinations.
The four countries met recently to develop a draft document on equivalence. The document will be submitted to the Codex Committee on Food Import and Export Inspection and Certification Systems for consideration prior to the next Committee meeting in February.
One change we want to make in U.S. Codex is to restructure the steering committee so that membership reflects the balance between regulatory issues and trade policy issues. We intend to invite representatives from the U.S. Trade Representative's office, the Commerce Department, and the State Department, to serve on the Codex steering committee so that the policy perspective is more fully represented.
Food safety is not just a USDA priority, but a priority of this Administration at the highest level. The President's commitment to improving food safety is evident in both his Food Safety Initiative, which he announced in January, and his initiative to ensure the safety of imported and domestic fruits and vegetables, which he just announced October 2. These two initiatives will help us to meet our food safety goals on a government-wide, and a commodity-wide, basis.
As you know, the President's Food Safety Initiative improves inspections and expands preventive safety measures, increases research into developing tests to detect foodborne pathogens and to assess the risks of foodborne illness, expands the FoodNet active surveillance system, establishes a national education campaign to improve food handling in homes and retail outlets, and establishes a new, intergovernmental group to further improve Federal, State, and local responses to outbreaks of foodborne illness.
Also, the President announced on October 2 his intention to send to the Congress proposed legislation that would require FDA to halt imports of fruits, vegetables, and other food from any foreign country whose food safety systems and standards are not on par with those of the United States. This legislation would be similar to existing law requiring the USDA to halt the importation of meat and poultry from such countries. The President also directed the Department of Health and Human Services to work with USDA, and in close cooperation with the agricultural community, to issue guidance on good agricultural practices and good manufacturing practices for fruits and vegetables.
Together, these two initiatives will help us to implement the comprehensive strategy I just described. I will be working closely with Congress, the Department of Health and Human Services, the Environmental Protection Agency, and the agriculture and food industry to see that these initiatives are put into place.
In closing, I believe we are making significant progress in our comprehensive, farm-to-table strategy for improving food safety. I look forward to working with many of you as we form partnerships to implement these initiatives. It's been a pleasure to share with you my priorities, and I would be happy to answer any questions you might have.
For Further Information Contact:
FSIS Food Safety Education and Communications Staff
Public Outreach and Communications
Phone: (202) 720-9352
Fax: (202) 720-9063
1997 Speeches | Current Speeches | FSIS Home Page | USDA Home Page