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The USDA Food Safety and Inspection Service’s statutory mandate as a regulatory enforcement agency can impede its ability to act proactively on food safety.
Ironically, the largest-ever food safety recall of poultry in 2011 has set the stage for improvements in collaboration in food safety among poultry companies and between governmental food safety agencies and the poultry industry. In the following interview, Mike Robach, vice president, corporate food safety and regulatory affairs at Cargill, discusses four keys to insuring continued improvements in the food safety of poultry.
1. Better communication is needed between the public health community and the poultry industry
Question: The USDA Food Safety Inspection Service’s statutory role as a regulatory enforcement agency poses something of a dilemma as it receives calls to be more proactive as a food safety agency. For example, where human illnesses associated with foodborne pathogens occur, should FSIS focus, first, on building a case for regulatory enforcement action or collaborate with the industry to identify sources and eliminate pathogens as quickly as possible from the food supply?
Mike Robach: Yes, that’s true, and we’ve had a number of conversations with the agency about this since Cargill’s turkey product recalls due to SalmonellaHeidelberg in 2011.
Cargill is working with several other poultry companies and the University of Georgia’s Mike Doyle and the Centers for Disease Control in a group that we are calling a Safe Food Forum. FSIS and FDA are participating in those meetings as well. The group is looking at ways of achieving better communication between the public health community and the poultry industry.
For example, when the public health community begins to see evidence of a cluster of human illnesses or potential outbreak, it would be helpful for them to be able to pull the industry into their discussions about potential sources. It would allow the industry to aid in an investigation as opposed to being subject to the investigation. This would be a big change.
The challenge is that FDA and USDA-FSIS have by statutory mandate a responsibility to take regulatory action once they are aware of something. That can often impede an effective investigation of root causes. We have to work through those issues, and that is the process that we are going through now.
2. Performance standards need to be more directly related to public health outcomes
Question: Performance standards are a pillar of FSIS policy. Do they benefit food safety?
Robach: Performance standards are a target or measuring tool for the industry to use in producing safer poultry. They can help drive outcomes, so I think that they are valuable. The performance standards being used today were probably the best available at the time that they were established. I would like to see performance standards changed to be more related to public health outcomes. That would drive industry performance in a positive way.
Question: Is there an example of performance standards linked to public health outcomes?
Robach: The performance standard for Listeria monocytogenes in ready-to-eat foods has driven industry efforts towards a significant reduction of this pathogen in ready-to-eat meats. That has resulted in reduced illnesses from Listeria related to the consumption of ready-to-eat meats. That’s a success story.
Question: What about performance standards for raw poultry?
Robach: Qualitative performance standards for the incidence of Salmonella in raw poultry, in my opinion, have not had the desired effect of reducing human salmonellosis. Reducing the incidence of Salmonella on poultry carcasses, in fact, has not resulted in a reduction of human salmonellosis. That tells me we should be looking at different performance standards to gauge the effectiveness of our interventions in raw poultry.
Question: Please give an example of a more effective performance standard.
Robach: In Iceland, it has been shown that if the number of Campylobacter cells on poultry are reduced to below 104 the incidence of campylobacteriosis in the human population is reduced. So, in that country, quantitative performance standards have resulted in positive public health outcomes. However, in the U.S., achieving reductions in Salmonella incidence levels with qualitative standards has not resulted in a reduction in human salmonellosis.
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Advantage of quantitative performance standards: Having 20 percent of carcasses positive with one cell is better than having 5 percent of carcasses contaminated with 1,000 cells each.
Having 20 percent of carcasses positive with one pathogen cell is probably a better place to be than having 5 percent of carcasses contaminated with 1,000 cells each. Clearly, we want to have a reduction in incidence to the extent possible, but the focus needs to be on getting the number of cells down because of infectious dose considerations.
Question: Should the focus be more on serotypes of public health significance?
Robach: I am a big believer in understanding and identifying virulence factors so that we can focus our efforts and resources on managing those organisms that are most capable of causing foodborne illness. If we can identify virulence factors that can be detected in a monitoring program, then we have a better chance of intervening and controlling those organisms. I think that is going to be an important technology to watch develop. A number of companies are working on identifying virulence factors and creating screens for those virulence factors.
3. Regulatory reform is needed to make FSIS oversight more science based
Question: HACCP is used in the U.S. regulatory framework in a way not originally intended as a scientifically based framework. Should FSIS policies be changed to be more scientifically sound?
Robach: When HACCP was made part of the Pathogen Reduction Act in 1996, FSIS was in a bind in that it had a statutory framework in which it had to operate. As a result, regulatory HACCP was born. It wasn’t based so much on risk assessment and hazard analysis as on existing regulations that had to be met. That is just an unfortunate reality.
Question: It is a reality now, but can it be changed?
Robach: The way to address this is to reform meat and poultry inspection legislation in the same way that FDA oversight is currently being reformed through the Food Safety Modernization Act. We need regulatory reform based on science with a focus on positive public health outcomes. That would require a rewriting of the legislation.
Question: What changes should be made in the regulatory framework?
Robach: When the Federal Meat Inspection Act was written in 1906 and when the Poultry Products Inspection Act was written in 1957, much of the focus was on diseased animals coming into the plant and not on microbiological food safety. I believe that the acts should be revised to focus more on identifying hazards, assessing risks, and having appropriate interventions in place to reduce risk to the extent possible. HACCP was originally designed to identify and eliminate hazards. Obviously, the risk of foodborne pathogens can’t be entirely eliminated in raw poultry. So the task is to reduce the hazard to an acceptable level from a food safety standpoint.
4. Poultry industry collaboration in food safety must continue, and new food safety research is needed
Question: How has Cargill been working with other companies on food safety?
Robach: One way is that Cargill has helped organize a group of meat and poultry companies and industry experts to share data about the risks involved in ground meat production and ground poultry production. Their purpose is to share data within the industry and develop hypotheses about the food safety risk in meat and poultry grinding operations. The group is also identifying the gaps in research and then taking an experimental approach to better understand how Salmonella moves through the system so that we can design more effective interventions.
Dr. David Acheson, who was formerly with FDA and USDA and now at Leavitt Partners, is facilitating and leading the group of industry experts. The first order of business has been to understand the dynamics of Salmonella in ground poultry. We have an extensive experience base with ground beef, and we are using our learning from the ground beef side to help shape the agenda for the ground poultry group.
Food safety shouldn’t be used as a competitive advantage. This kind of collaborative approach has been used on the ground beef side for some time. It is great to get the whole ground meat community working together on food safety.
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HACCP was designed to identify and eliminate hazards of foodborne pathogens with a kill step such as cooking – something not applicable in raw poultry.
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Cargill helped form an industry group that shares data and develops hypotheses about the food safety risk in meat and poultry grinding operations.
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