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Web Content Viewer (JSR 286)

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Web Content Viewer (JSR 286)

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Web Content Viewer (JSR 286)

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FSIS Livestock Slaughter Establishment Residue Questionnaire Results

 

On May 28, 2014, FSIS issued FSIS Notice 24-14, Livestock Slaughter Establishment Residue Questionnaire, with instructions to Public Health Veterinarians (PHVs) to gather data about factors that may affect the performance of in-plant screening tests.  The questionnaire began June 1 and ended June 30, 2014.   The PHIS assigned questionnaire produced completed PHV responses from 796 establishments; however, multiple PHV responses were received from several establishments.  In addition, several of the questions allowed multiple answers so this also resulted in answers that exceeded the 796.  FSIS intends to use the responses to the questionnaire to assess what factors influence the ability of PHVs to implement residue sampling instructions as intended and to develop strategies to enhance the effectiveness of those instructions.

  1. PHVs were asked to identify in which document the establishment addresses residues.
    The majority of responses (432) indicate establishments address residues in their HACCP plan or in a prerequisite program (341).   The third most common answer selected was that the establishment does not address residues (156).  Some PHVs selected pre-slaughter controls at the livestock production unit (79) or a Sanitation SOP (17). Only a few responses indicated that residues were addressed as a critical control point (9).

  2. The PHVs were asked to select the statements that describe the establishment's residue control program (other than testing). 
    The response selected most frequently was that the establishment does not have a residue control program (354).  For establishments with residue control programs, the responses were selected in this order:   the establishments have residue control programs that are written (349), the residue control program is available for FSIS review (325), the establishment adheres to their program (285), the program creates and maintains records (223), the program identifies elements of FSIS’ sampling as part of their program (222), the program requires residue-free certification from all suppliers (186), the residue control program has pre-slaughter controls (108), and the program has decreased the number of violative residues (48).  The least selected answer was pre-testing of livestock from all suppliers (2).

  3. The PHVs were asked to select the statements that describe this establishment's residue testing plan.
    The vast majority responded that the establishment does not have a residue-testing plan (753).  Of the establishments that have a residue-testing plan, the responses in decreasing frequency were:  the residue testing plan is written (74), the residue testing plan is available for FSIS review (71), the plan creates and maintains records (58), the establishment adheres to its plan (56), the plan implements pre-slaughter testing at livestock production units (18), and the residue testing plan has decreased the number of violative residue results (7).

  4. PHVs were asked to select the statements that describe residue testing at this establishment.
    The majority responded that the establishment does not conduct its own residue testing (802).  Of the responses at establishments that conduct their own residue testing, the top response was that the establishment performs residue screen assays only (20), followed by the establishment performs screening and submits the screen positives to an outside lab (19).  The least selected response was that the establishment collects samples and submits them to an outside lab (15).

  5. FSIS asked PHVs if there are livestock production units (producers) supplying animals to this establishment that have residue avoidance programs due to requirements in the establishment's residue control program.
    The majority answered “no” (692) but around one-third of the responses were “yes.” (246).

  6. FSIS asked if the establishment provides FSIS the livestock producer name and address for carcasses found to have violative levels of residues by the FSIS laboratory.
    The majority of the responses were “yes” (465) with “not applicable” being the next most common response (370).  A few responded “no” (14).

  7. PHVs were asked to select and rank the top seven most significant reasons to not perform residue testing from greatest to least.
    The top response was that there was no reason to not test (542).  For the reasons that were selected to not test, starting with the most frequently selected:  professional discretion (473), carcass condemned (337), and no specific instruction (305).  286 PHVs selected the time needed to enter information into PHIS as a reason to not residue test.  Staffing issues like rotation (277) and vacancies (262) were next, followed by a lack of supplies (253), “other” (240), and office space needed for testing equipment (207).  Inspector training (179) was selected next, followed by perceived FDA inaction (176), frozen storage space (143), and establishment cooperation (123).  The least selected includes KIS test block availability (113), lack of enforcement action (109), PHV training (85), and establishment repercussions (70).

  8. The PHVs were asked to provide other barriers from Q.7.
    Small establishment slaughtering healthy livestock was the reason for the majority of the answers (127).  The second most frequent response was that there were no barriers; they do test (88).  The other reasons for not testing include time (25), staffing shortage (14), shortage of KIS equipment or supplies (4), and vacant positions (4).

  9. The PHVs were asked to list and rank the top 5 time-consuming inspection tasks out of a list of 18 possible choices. 
    The most frequently selected choice was HACCP duties (614), followed by post-mortem/on line inspection duties (588), humane handling (540), Sanitation SOP (497), and ante-mortem inspection (419).  PHIS non residue entry was the next selected time-consuming task (402) and was followed by plant discussions (261), travel (252), email (247), pathology/dispositions (193), and then personnel issues (161).  The least selected choices include residue in-plant testing (141), residue PHIS entry (107), residue-directed sampling (99), other generic E. coli (74), other records (72), and NR appeals (60).

  10. The PHVs were asked to provide other time-consuming tasks from not identified in Q.9.
    The reasons provided include other sampling (11), PHIS data entry (9), exports (4), AgLearn (2), and verifying sanitary dressing (1).

  11. Veterinarians were asked to select from a list of decision criteria which factors they use to support a decision not to select a carcass for residue testing when the carcass demonstrates a condition that may warrant testing.
    The most frequently selected responses were the establishment only slaughters healthy livestock (401) and the veterinarian had not previously found violative residues in livestock from the producer (297).  The next most frequently selected responses were: IPP have the authority to test fewer carcasses if establishment history supports the decision (181) and the list of conditions that may warrant testing does not apply to the market class slaughtered (169).  The selections identified least frequently were when the carcass is condemned (148), and the IPP have the authority to test fewer carcasses if producer history supports the decision (119).

  12. FSIS veterinarians selected a set of responses that they find helpful when determining which carcasses to test for residues.
    Generally, respondents prefer to strengthen inspector awareness of the pathological conditions that warrant testing for residues (406).  Additionally, respondents favor more definitive carcass selection criteria (348).  The rest of the responses, in order of emphasis from most to least, were: provide IPP guidance on how to assess their level of in-plant testing (333), require veterinarians, food inspectors and consumer safety inspectors to test a percent of carcasses for each market class (262), provide an explanation on how to prioritize performance of residue tasks (229), and strengthen FSIS veterinarians’ awareness of pathological conditions warranting residue testing (228).

  13. FSIS veterinarians were asked to share an approach or a strategy they use when implementing FSIS’ residue program that they considered helpful to other FSIS veterinarians.
    The top two responses were 1) perform the screen test  based on the observations made from antemortem and postmortem inspection observations (59) and 2) work with the consumer safety inspectors to enhance the inspectors’ awareness of FSIS’ policy and pathological conditions that may warrant testing for residues (47).  Additionally, veterinarians recommend the following steps be taken:  follow the existing policy (20), post a list of pathologies warranting testing in the FSIS inspection office (19), post the residue violator list and refer inspectors to the list(6),  ensure carcasses demonstrating conditions of acute disease are tested (5), and finally, a small percentage of veterinarians suggest testing all condemned carcasses (4).

  14. FSIS asked whether field staff consider antemortem inspection findings when selecting carcasses for drug residue testing.
    Most of the respondents selected “Always,” indicating veterinarians considered antemortem findings and postmortem findings when selecting carcasses for in-plant residue testing (383).  Many veterinarians reported they either “occasionally” (220) or “frequently” (186) consider antemortem observations when deciding if a carcass should be tested for residues.  A small percentage of the responses showed that antemortem observations are not used when deciding to test a carcass (53).

  15. Respondents identified the residue tasks performed by Food Inspectors or Consumer Safety Inspectors at the establishment.
    The survey identified the process of selecting carcasses for testing and the performance of the many features of the testing program as separate elements, and the survey asked veterinarians to identify which parts of the testing program were completed by inspectors.  The parts most frequently selected were: tissue sample collection (641), security of samples (634), collection of all animal identification (581), carcass selection at postmortem for residue testing (565), setting up the residue test (KISTM Test)(562), security of animal identifications (554), entering the information into PHIS (529), and inspectors perform all aspects of the FSIS in-plant residue program (515).  Additional tasks performed by inspectors included selecting animals for residue testing during ante-mortem inspection (399), and some inspectors enter test results in another record system, such as Microsoft Excel or Word (152).

  16. Veterinarians were asked to report the total number of hours all FSIS personnel at the assigned establishment spend performing all aspects of FSIS' in-plant residue program.
    Most respondents said they spend less than 1 hour per shift executing FSIS’ residue program (560), followed by 1 hour to less than 2 hours (173), 2 hours to less than 3 hours (52), 4 hours or more was next (31), followed by 3 hours to less than 4 hours (25).

  17. FSIS asked veterinarians to identify what actions the establishment took to prevent the slaughter of livestock that have violative residues by selecting from a list of actions that establishments could implement.
    The most frequent response was that the establishment did not have to address violative residues because FSIS never found a violative residue in livestock slaughtered at the establishment (489).  Other responses identified include: buying directly from producers (282), provide supplier information to FSIS at the time of antemortem inspection (239), notify producers of all residue findings (221), establishments verified supplying producers are not on the Residue Repeat Violator List (179), and the establishments stopped buying livestock from the repeat violator (121).

    Additional actions taken included: establishments started their own in-plant residue control program (75), identifying drug residues as reasonably likely to occur in the establishment’s hazard analysis (55), establishments improved their animal segregation practices (31), establishments reassessed the hazard analysis when there are changes in suppliers (24), and started live animal testing (7).

  18. FSIS asked veterinarians to identify additional actions that establishments took to prevent the slaughter of livestock that have violative residues.
    In order of predominance, the responses include: purchase from known suppliers with good reputations (29), require certificates or producer affidavits (27), slaughter only healthy animals (20), discontinued business with suppliers of residue positive livestock (9), all suppliers are notified of violations (8), the establishment provides educational information on residues (7), the establishment does not or rarely slaughters high risk production classes (6), the establishment monitors herd records (6), the establishment does not buy from sale barns (6), and  the establishment provides FSIS with animal identification (3).

    Veterinarians also reported the following actions were taken by establishments.  A few establishments increase testing when violations are identified (3), make suppliers liable for violations (2), require suppliers to check the repeat violator list for names of owners of livestock shipped to the establishment (2), hold livestock prior to slaughter (2), use end-user specifications (1), performs its own ante-mortem and postmortem check (1), post signs in the pen area indicating that the establishment will not accept livestock with drug residue (1), and maintains and updates list of known violators.

  19. FSIS asked veterinarians to identify those actions, from a list of actions, which FSIS took in the establishment because of multiple residue violations.
    The most common response was that no actions had been taken because the establishment has not had to address multiple violative residues (683).  For those establishments that experienced multiple residue violations, veterinarians reported that FSIS took the following actions: increased testing of carcasses (71), documented discussions with establishment officials on memorandum of interviews (63), authored noncompliance records (50), linked noncompliance reports (15), and district offices issued either a Notice of Intended Enforcement (9) or Notice of Suspension without prior notification (2).

  20. Veterinarians were asked to provide any additional comments they may have about FSIS taking action due to multiple residue violations.
    Some respondents thought FSIS should increase residue testing on livestock from brokers that handled violative livestock and producers who sold livestock with violative residues (7).   They also express concern regarding suppliers changing their names in order to evade the repeat violator list protocols (6).  Some veterinarians responded that FDA should take on greater responsibility and take stronger action against violators (3).

  21. Respondents provided additional comments about the establishment's residue control program or testing plan that were not addressed in the rest of the survey.
    Several veterinarians reported that establishments relied solely on National Residue Program testing and FSIS’ residue program (14).  Several reported establishments address residue in HACCP plans and determined residues are a hazard not reasonably likely to occur (13).  Respondents report establishment-based practices included: residue testing to support export requirements (2), marking swine to identify hogs to be used for producing export product and specific domestic distribution(1), and establishments are purchasing hogs from producers certified by National Pork Board’s Quality Assurance Program (1).

Conclusion:  The 2014 Residue Questionnaire results indicate a need for more specific instruction and training for PHVs on when to residue test.  The responses from the PHVs indicate that there is some confusion with the current instruction, and, further, those instructions should be more slaughter class specific.  Staffing shortages and interference from other inspection responsibilities continue to be a reason to not residue test.  The results of this questionnaire were used to initiate the FSIS Slaughter Pilot project which FSIS intends to start in October.

Last Modified Jan 26, 2016