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Food Safety and Inspection
Service United States Department of Agriculture Washington, D.C. 20250-3700 |
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Food Safety and Inspection
Service United States Department of Agriculture Washington, D.C. 20250-3700 |
Speeches
Food Safety and Inspection Service
U.S. Department of Agriculture
Remarks prepared for delivery by Thomas J. Billy, Administrator, Food Safety and Inspection Service, U.S. Department of Agriculture, before the World Health Organization Consultation on Pre-Harvest Food Safety, March 27, 2001, Berlin, Germany.
Good afternoon. In my remarks earlier today regarding Codex’s role in pre-harvest food safety, I emphasized that the pre-harvest food safety area poses particular challenges for a number of reasons. First, compared to other segments of the farm-to-table chain, there is limited information on practices that will improve pre-harvest food safety. Second, national governments have varying authority, access—and thus, influence—over this segment of the farm-to-table chain. And third, numerous variables such as farm practices, animal health, economics, and the environment complicate our ability to make positive changes.
Despite these challenges, for the past five years, the United States has implemented a farm-to-table food safety strategy to respond to the burden of foodborne illness in the United States. The latest data from the Centers for Disease Control and Prevention estimate 76 million cases of foodborne illness, 325,000 serious illnesses resulting in hospitalization, and 5,000 deaths each year. This strategy is based on the philosophy that "those in control of each segment must bear the responsibility for identifying and preventing or reducing food safety hazards."
The cornerstone of this strategy is the 1996 Pathogen Reduction and HACCP systems final rule, which set new requirements for all meat and poultry plants to improve food safety. It mandated HACCP, sets performance standards for Salmonella, and requires plants to test for generic E. coli and implement standard operating procedures for sanitation. The results of this rule have been significant in terms of reductions in Salmonella on meat and poultry products and reductions in human illnesses each year since 1996.
While the rule set requirements only for meat and poultry plants, the rule has had, as expected, a ripple effect among producers. As plants have to meet new requirements, they in turn are placing new food safety requirements on their suppliers. This also occurred when USDA declared E. coli O157:H7 an adulterant in ground beef and began a testing program for the pathogen—plants began to set additional requirements for incoming raw materials. And it has occurred in response to the Food and Drug Administration’s ban on the feeding of ruminant-derived protein in feed for ruminant animals. IBP, a major meatpacker, is requiring its cattle buyers to have suppliers sign an affidavit verifying compliance with the feed ban.
Pressure also is coming directly from the retail industry. For example, beginning April 1, McDonald’s Corporation is requiring packers to document that all materials fed to cattle comply with government regulations prohibiting the feeding of ruminant-derived proteins to cattle. A move such as this from a large corporation will have a profound effect on producers. It shows how the marketplace is driving change in preharvest food safety.
This ripple effect is leading to a greater emphasis on third-party certification programs. As Dr. Blaha described yesterday with his "Minnesota Certified" project, these programs are being implemented to assure purchasers that certain animal production food safety practices are certified by a competent authority. USDA in fact developed such a system in response to the European Union’s requirement that cattle exported to EU countries not be treated with hormones. USDA developed guidelines for the industry and implemented a third-party verification program.
Let me turn to a discussion of our preharvest food safety strategy. While USDA’s Animal and Plant Health Inspection Service, the U.S. Food and Drug Administration, and the States have authority on the farm, the Food Safety and Inspection Service (FSIS) has none. We decided not to wait for new authority but to do what we could under our current authority and help producers prepare for the ripple effect I just described.
To that end, we are working with producers to educate them about pre-harvest food safety and to encourage them to voluntarily adopt HACCP-compatible practices. By HACCP-compatible, I mean that these are not mandatory HACCP programs such as those in place within meat and poultry plants. Rather, verifiable practices are implemented to prevent microbial, physical, and chemical hazards. This way, when companies set requirements for incoming animals to address food safety concerns, producers are ready to accommodate these requirements.
At the same time, FSIS is encouraging research on pre-harvest food safety so that we can learn more about what specific steps can be taken at the production level to minimize hazards. FSIS is not a research Agency, but we provide guidance to government agencies that conduct research, academia, and industry to encourage them to conduct priority food safety research.
A third way FSIS is involved in pre-harvest food safety is by conducting farm-to-table risk assessments to identify target areas for hazard reduction all along the farm-to-table chain. This enables risk managers to determine optimal practices to reduce the risk of foodborne illness.
Let me talk about these areas in more detail.
Educating producers has been a challenge because of the need for an infrastructure to communicate messages to this audience. FSIS works cooperatively with groups within and outside government—we call them information multipliers—in order to get the word out about the value of good production practices in improving food safety. For example, we have government agricultural extension specialists in each county in the United States who work directly with producers to help them with any problems. USDA has a cadre of more than 25,000 accredited veterinarians who work with producers. Thus, we can spread the word quickly by using this infrastructure that is already in place. We also pay close attention to small and disadvantaged producers, who may need more help in meeting the demands of the marketplace. One of the ways we do that is to fund programs at educational institutions that serve African American, Hispanic and Native American producers in disadvantaged rural areas.
One of our most successful endeavors has been the establishment of partnerships at the local level. We support state animal health agencies in educating food animal producers on how to adopt HACCP-compatible production practices. Producers develop quality assurance programs that may contain a number of HACCP-compatible practices, including:
the judicious use of pesticides, biologics and animal drugs;
improved feed and water quality;
animal waste management;
animal identification;
record keeping of management practices;
certification programs between animal suppliers and purchasers;
biosecurity measures to improve herd health and hygiene, and
good sanitation practices.
During the last two years, FSIS funded 24 state partnerships. They differ from state to state depending on what is the best approach for each specific location and how much experience each state has had developing such programs. What works in one state may not be possible in another.
In addition to establishing partnerships with states, we also work with specific commodity groups. An example is the Trichina-safe pork certification program that we have established with the pork industry. Under this program, USDA accredited veterinarians audit trichina control practices on the farm and conduct live animal tests. For example, the model defines farm management, biosecurity, food and feed storage safety, rodent control, and general hygienic practices. This program serves a dual purpose—it improves food safety and it’s a marketing tool for industry. We hope that with further research, the concept can be applied to other foodborne microbial pathogens.
Another activity we are pursing is the development of guidelines for producers to accompany policies we set for plants that are under our regulatory control. The goal is to help producers prepare for the ripple effect that occurs when we set new requirements. For example, we are developing guidelines for producers to address E. coli O157:H7. Although we don’t have specific practices that have been shown to reliably reduce pathogens on carcasses, good production practices that address recordkeeping, general sanitation, water and feed security may be expected to help control the spread of zoonotic pathogens.
I want to emphasize that producer organizations also play an important role in educating producers. USDA cannot, nor should it, do the job alone.
As I said earlier, one of the challenges to improving food safety at the pre-harvest level has been a lack of information on practices that will improve pre-harvest food safety. We know that good management practices on the farm addressing areas such as feed and water quality help, and we have a lot of experience in controlling chemical residues. But more research is needed to determine specific and practical ways to reduce pathogens in and on live animals. USDA plays a large role in sponsoring such research, and industry contributes to this body of knowledge as well. It is important that we share this information internationally so that we can all benefit.
We know that there is no single solution--multiple intervention hurdles based on science need to be implemented by producers. A number of promising interventions are being studied, including microbial competitive exclusion, diet management, feed additives, vaccines, and water sanitizers.
E. coli O157:H7 is a particular concern in cattle. Scientists have experimentally reduced infections by fasting cattle for 48 hours then refeeding. Reducing biofilms in water troughs, acidifying feeds and reducing hide contamination are other interventions being studied for this pathogen. Scientists from the University of Wisconsin recently decoded the genome for E. coli O157:H7, which could lead to the development of a vaccine for cattle.
Farm-to-table risk assessments are another important activity that addresses the pre-harvest area. Risk assessments are closely tied to research because they help to identify data gaps that need to be addressed.
In 1998, USDA completed a farm-to-table risk assessment for Salmonella Enteritidis in shell eggs and egg products. By making this a farm-to-table risk assessment, we were able to identify target areas for risk reduction all along the farm-to-table chain. As a result of the risk assessment, government agencies with shared jurisdiction over eggs worked together to develop an Egg Safety Action Plan, which identifies the systems and practices that must be implemented from farm-to-table to reduce and ultimately eliminate eggs as a source of human Salmonella Enteritidis illnesses.
For example, at the farm level, the Food and Drug Administration (FDA) would develop standards for producers for such things as cleaning and disinfection and biosecurity, and the states would provide inspection and enforcement on the farms.
Within federally inspected plants, USDA would require a HACCP-based system for egg packers and processors.
At the retail level, Federal requirements would be established for cooling and holding foods containing eggs.
These are just three examples to illustrate how the plan encompasses the entire farm-to-table chain. This is the first formal, farm-to-table action plan that has been developed by the U.S., and we expect it to serve as a prototype for future plans. The various agencies with responsibility for egg safety are now working to implement various parts of the plan.
To meet the growing need for risk assessments to help set food safety policies, FSIS is planning to establish a Risk Assessment Center within the Agency.
For the future, we will continue to support all of these activities—partnerships with local communities and commodity groups, research, and risk assessment.
In addition, we are exploring ways to better involve our veterinarians at the pre-harvest level. For example, they could be more involved in cooperative producer education programs, disease traceback, and residue avoidance.
In closing, I have three recommendations:
First, new requirements for meat and poultry plants should be designed to have a ripple effect on the production segment of the farm-to-table chain.
Second, partnerships are critical to making significant improvements in the preharvest areas.
And third, science, through risk assessment, is the key to developing effective risk reduction strategies.
Our ultimate goal must be to bring producers into the food safety business in order for the farm-to-table chain to stay connected and be effective.
For Further Information:
FSIS Congressional and Public Affairs Staff
Phone: (202) 720-3897
Fax: (202) 720-5704
