2010-2012 Subcommittee: Study of Microbiological Criteria as Indicators of Process Control or Insanitary Conditions
Food Safety Questions from the USDA Agricultural Marketing Service to Support Ground Beef Purchase for the Federal Food and Nutrition Assistance Programs
- Mr. Spencer Garrett: Working Group Chair
- Dr. Robert Dole
- Dr. Kathleen Glass
- Dr. Stephen Knabel
- Ms. Angela Ruple
- Dr. Robert Whitaker
- Dr. Donald Zink
The U.S. Department of Agriculture's (USDA) Agricultural Marketing Service (AMS) purchases and distributes food for various federal food and nutrition programs that feed millions of Americans daily. USDA is committed to supplying safe, wholesome and nutritious food to participants in these programs. The National School Lunch Program (NSLP) is one of those programs. Ground beef is among the many items that USDA purchases under this program. AMS develops purchase specifications and conducts the purchases of the ground beef products for distribution through the Food Nutrition Service and the Farm Service Agency.
In developing the food safety requirements of the Federal Ground Beef Purchase program, AMS uses an appropriate risk-based food safety strategy and the development and implementation of microbiological criteria based on scientific principles. In this regard, AMS asks the National Advisory Committee on Microbiological Criteria for Food (NACMCF) to rigorously evaluate the microbiological criteria of the Agency's ground beef purchase program and provide recommendations. AMS will seek NACMCF's advice in two separate work charges. This request is the smaller and first of the two requests and represents AMS priority needs to assist their purchase of ground beef for the 2012-2013 school year. The larger work request will cover all food safety requirements of the Federal Ground Beef Purchase program and will be submitted to NACMCF at a later date.
Food suppliers to USDA must adhere to strict nutritional, food safety, and quality requirements. AMS uses a complete food safety strategy that encompasses more than the testing of samples to determine the safety and quality of the product. AMS ground beef purchase specifications go beyond industry food safety requirements mandated by the Food Safety and Inspection Service (FSIS). Additional safeguard requirements include rigid time and temperature stipulations for the chilling and/or freezing of raw and finished product, tamper-evident packing and additional facility inspections. AMS requires suppliers (raw material) and contractors (finished product) to the Federal Purchase Ground Beef Program to use statistical process control methods and requires product (raw material and finished product) to be tested for indicator organisms (aerobic plate count, total coliform, generic Escherichia coli, and Staphylococcus aureus) and pathogens ( Escherichia coli O157:H7 and Salmonella). AMS has a zero tolerance for the pathogens and defines the critical limits for each of the indicators. AMS' food safety requirements can be found in the Technical Requirements Schedule for Ground Beef (TRD-GB) (visit http://www.ams.usda.gov/LSSTDZ and click on the Federal Purchase Program Specifications link on the right-hand side in the "I want information on" box).
The requirements for the Federal Ground Beef Purchase program are reviewed each year in order to continuously improve the quality and safety of the purchased products and overall program controls. As part of this process, AMS requests that NACMCF review current practices and develop specific recommendations concerning the issues outlined below.
Charge Questions for the Subcommittee
- AMS is considering eliminating the requirement to test for Staphylococcus aureus from the Federal Purchase Ground Beef Program and AMS asks NACMCF to provide considerations and scientific discussion regarding this action with respect to public health.
- Should AMS consider the use of alternative screening procedures beyond those stipulated in the FSIS Microbiology Laboratory Guidebook (MLG), and if so, would the AMS testing program results be comparable to FSIS' verification testing programs, and therefore useful to FSIS? What should be considered in distinguishing acceptable and unacceptable alternative screening procedures? Is it appropriate to allow alternative sample preparation procedures (portion size, enrichment broth, portion to broth ratio, enrichment time and temperature) which differed from the MLG, or which differed by AMS designated laboratory?
- AMS asks NACMCF to evaluate boneless beef and finished product compliance program lotting and frequency of testing for pathogens and indicators of process control for both raw ground beef to be cooked on-site at schools with unknown cooking controls versus raw product destined to be cooked in a USDA inspected establishment.