|Food Safety and Inspection
United States Department of Agriculture
Washington, D.C. 20250-3700
Remarks prepared for delivery by Thomas J. Billy, Administrator, Food Safety and Inspection Service, before the National HACCP Education Conference, October 6, 1997, Atlanta, Georgia.
It's a pleasure to be here today at this National HACCP Education Conference. I appreciate the work the Cooperative State Research, Education and Extension Service and the Cooperative Extension Service are doing to implement model HACCP education programs in each state.
I congratulate all of the team members on recognizing two very important points. First, that partnerships are critical to our success. All of us--government, industry, academia, and consumers--are in this fight against foodborne illness together, and none of us can do the job alone. And second, that we must always keep a broad, farm-to-table focus when finding solutions to our food safety problems. It will require multiple efforts all along the farm-to-table continuum for real progress to occur.
This initiative addresses both of these important points, and I welcome the opportunity to be part of this important partnership.
I am here today to talk about HACCP, and specifically about how important HACCP education is to the achievement of our food safety goals. I'm sure you already know that the Food Safety Inspection Service (FSIS) is the USDA agency responsible for ensuring the safety of meat, poultry, and egg products. Our inspectors enforce food safety requirements at privately-owned plants across the country, and we also inspect imported products before they can enter U.S. commerce.
In 1994, following an outbreak of foodborne illness that was attributed to E. coli O157:H7 in undercooked hamburgers sold at a fast food restaurant, we began a strategy for change in our food safety programs. That outbreak was certainly not the first outbreak of foodborne illness in the United States, and we have known for some time that changes were needed. But this outbreak provided a national impetus for ground-breaking change.
We have accomplished quite a bit since then. In 1996, after a thorough public process, USDA published its landmark rule on Pathogen Reduction and Hazard Analysis and Critical Control Points (HACCP). That rule requires all plants that slaughter and process meat and poultry to implement HACCP systems as a means of preventing contamination from pathogens and other hazards. The preventive approach that is embodied in HACCP is an important principle in our fight against pathogens, because we all know you cannot ensure the safety of a product through testing. Prevention must be our first line of defense.
To make sure HACCP systems are working as intended, the rule also sets in-plant performance standards for Salmonella, and FSIS will conduct testing to ensure these standards are being met. Because Salmonella, E. coli O157:H7 and other pathogens are associated with fecal contamination, the rule also requires slaughter plants to routinely test carcasses for generic E. coli, an indicator of fecal contamination. And the rule requires all plants to have in place standard operating procedures for sanitation.
We are now implementing the final rule. As of January 27, 1997, all plants were required to have in place standard operating procedures for sanitation, and slaughter plants were required to begin testing for generic E. coli. HACCP implementation begins in January 1998. We are implementing HACCP in stages, with the largest plants having to implement HACCP first. By January 2000, all plants will have HACCP in place.
As we developed this strategy for change, an important guiding principle was the need to clarify the respective roles of industry and government in ensuring the safety of meat and poultry products. Companies producing meat and poultry products are responsible for ensuring that their products are safe. Government is responsible for verifying that its requirements have been met and for taking appropriate remedial actions when the requirements have not been met.
While this concept makes perfect sense, we knew that clarifying the respective roles of government and industry would require a massive culture change on both sides--government and industry. I emphasize this point, because achieving this culture change as we implement HACCP is perhaps the most difficult educational challenge before us.
Implementation of HACCP and the other provisions of the final rule within federally- and state-inspected plants is a significant step, but it is not the only step we must take to reach our food safety goals. We must also encourage HACCP concepts farm to table. From the very beginning, we have known that an effective food safety strategy must address the entire farm-to-table continuum, not just what goes on within inspected plants.
We recognize that each sector in the farm-to-table continuum is at a different level when it comes to applying HACCP-type approaches, and I know you are considering this as you develop your plans. With the final rule on Pathogen Reduction and HACCP, plants know what they are expected to do. We are ready to implement HACCP at this point in the farm-to-table.
But at other levels of the continuum, things are not so crystal clear. At the animal production level, for instance, we don't really know what management practices will reduce pathogens, although we are making some progress. But even with some uncertainties, it is possible to implement HACCP-type approaches farm-to-table.
And that should be our goal. We believe that each sector in the food system is responsible for doing whatever it can to improve food safety practices based on what is currently known. As science and technology improve, and this is happening very rapidly, scientific principles for reducing pathogens and other hazards will emerge, and we expect each sector to take full advantage of these developments to improve food safety.
We are making progress by working closely with other government agencies that share food safety regulatory responsibilities, professional groups, academia, and industry to encourage the adoption of HACCP-type systems all along the farm-to-table continuum. Federal-state cooperation at points outside of federally-inspected plants is critically important because the States are involved in all facets of food production, marketing, and education. Our involvement does not mean we necessarily believe that Federal regulatory measures are needed. We are considering a full range of options, in cooperation with the States, including non-regulatory measures such as voluntary programs and education.
The animal production area--that is, on the farm and during intermediate stages before animals reach the slaughter plant--is an example of where we do not envision the type of direct regulatory role that we have at federally inspected establishments. FSIS is primarily working with producer groups toward the voluntary application of food safety assurance programs, based on HACCP principles.
For example, we have a steep learning curve when it comes to finding ways to reduce pathogens during animal production. That's why pre-harvest food safety research is highlighted in the President's Food Safety Initiative, and FSIS is guiding and supporting applied studies that will tell us what really works and what is practical in real-life situations.
Despite this data gap, there is a lot we can teach the animal production community right now. They should know HACCP principles. They should know that HACCP can help them to prevent chemical residues. And they should know the importance of implementing the quality assurance programs developed by their specific commodity group, and of following humane handling practices.
At the transportation to retail level of the farm-to-table chain, we are ahead of where we are at the animal production level in terms of knowing what practices can improve food safety. We are working with the Food and Drug Administration (FDA) to develop standards governing the safety of foods during distribution. We are placing particular emphasis on time and temperature control as a means of minimizing the growth of pathogenic microorganisms, as well as on sanitation. Once such standards are in place, we are committed to providing inspection personnel to ensure that these standards are complied with for meat, poultry, and egg products.
At the retail level, we are again working with FDA, and with State officials, to ensure the adoption of science-based standards that foster HACCP-type preventive approaches. We recognize that the primary responsibility for overseeing food safety at the retail level resides properly with State and local governments. We fully support the Food Code process and the role of the Conference for Food Protection in developing the best model code possible for State adoption.
In addition to working through the Food Code, we also want to provide assistance to State and local regulatory agencies, through training and other means. For instance, working with the Association of Food and Drug Officials, we recently began a series of training sessions for State and local food inspection agencies on the potential health risks associated with meat and poultry products processed at the retail level and in food service operations. This is a good example of the type of assistance we want to provide.
Education is also needed at the consumer level. We can't implement HACCP in the home, but we can help consumers pay close attention to practices they follow that may compromise food safety. It's not enough to provide information, however--we must change food safety behavior. In June, USDA, in cooperation with FDA and the Centers for Disease Control and Prevention, sponsored a conference to discuss how we can accomplish such change. And we will soon announce a new education campaign for consumers that is a result of a government-industry partnership. Susan Conley will talk more about our consumer education activities this afternoon.
The ultimate goal, and challenge, is to successfully implement this farm-to-table food safety strategy, and that is where we believe your state teams can help. In fact, they are critical.
One major challenge we face is to implement HACCP in plants, particularly in very small plants. All plants, regardless of size, are required to implement HACCP. But the small plants will have the toughest time because they do not have the same resources as large plants. I believe some numbers will illustrate the challenge. We have more than 6,000 Federal and more than 2,200 State plants. Of the Federal plants, only 314 are large--the remainder are split between the "small" and "very small" categories. Of the State plants, nearly all are very small.
We are well aware of this challenge and have a number of on-going activities to assist small plants. Dorothy Stringfellow will be discussing these in more detail, so I will mention them only briefly. First, we have available 13 generic HACCP models to facilitate preparation of HACCP plans. Second, we are conducting HACCP demonstration projects for "small" and "very small" plants to demonstrate how these plants can meet the HACCP requirement well before their regulatory deadlines. Third, we have available two publications to assist in the preparation of HACCP plans--Guidebook for the Preparation of HACCP Plans, and the Meat and Poultry Hazards and Control Guide.
As you prepare your state plans, please include as one of your activities providing technical assistance to small plants implementing HACCP.
We also need help implementing HACCP principles farm to table. Out of necessity, this must be a cooperative effort that depends heavily on partnerships among government, industry, academia, and consumers.
We believe our regulatory requirements in plants will have a ripple effect along the farm-to-table chain, in that market forces will influence change outside of plants. For instance, as plants are expected to meet the requirements of the final rule, they will expect their suppliers to provide raw materials and ingredients that meet certain food safety specifications.
But we know that market forces, alone, will not do the job. We need to educate those involved in producing, transporting, selling, and preparing food, including consumers. Those of you who are education experts know that changing behavior is complicated and requires repeated efforts. We need you to help them understand their role in food safety and to accept their responsibilities.
In closing, I appreciate any help you can give us to successfully implement HACCP in plants and HACCP concepts throughout the farm-to-table chain. We will be happy to provide whatever assistance you need as you develop your state plans for HACCP education. By working together, we can make significant progress toward our food safety goals.
For Further Information Contact:
FSIS Food Safety Education and Communications Staff
Public Outreach and Communications
Phone: (202) 720-9352
Fax: (202) 720-9063
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