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1
Executive Summary
According to the U.S. Department of Agriculture (USDA), the role of its Food
Safety and Inspection Service (FSTS) is "to set policies and regulations, based on the
best possible science to protect public health and to foster public confidence in the
safety of our food" (Smith, 1990, p. 7~. "In the next decade, FSIS intends to complete
the transition from an inspection service to a public health agency capable of
controlling risks from the producer to the consumer with the aim of reducing
foodborne illness acquired through consumption of meat products" (Crawford, 1990, p.
12~.
FSIS has proposed the Streamlined Inspection System for cattle (STS-C) as the
first step in modernizing slaughter inspection of fed cattle.7 The Committee on
Evaluation of USDA's SIS-C, established within the Food and Nutrition Board of the
Institute of Medicine, National Academy of Sciences, studied fed-cattle inspection
procedures with the FSIS goals in mind. Its analysis was also influenced by the
following factors:
o
o
Meat quality and meat safety are not synonymous. Although there is
overlap, meat quality largely depends on palatability factors,
aesthetically pleasing appearance, freedom from visible lesions and
foreign materials, and good keeping characteristics. Meat safety
deals with the presence of microbial pathogens and levels of chemical
residues.
Contemporary foodborne illnesses are associated with pathogenic
microbial contamination and possibly chemical residues. Neither are
detectable by traditional inspection methods. Traditional meat
fifed cattle comprise young castrated males (steers) and young females that have
never calved (heifers); both are fed special finishing rations in feedlots immediately
prior to slaughter. This class of cattle is usually slaughtered in large packing plants
with fast line speeds. They are usually uniform in age, size, and weight and have fewer
condemnable conditions than do nonfed cattle or cull cattle that are sent to slaughter
because it is no longer economically feasible to maintain them. SIS-C as evaluated by
the committee is intended for use in high speed operations slaughtering largely fed
cattle. It is currently not FSIS's intention to extend SIS-C to operations slaughtering
classes of cattle (e.g., veal calves and daily cattle) that tend to have higher incidences
of chemical residues and condemnable defects that are detectable at inspection.
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inspections emphasizes visible abnormalities more relevant to quality
than to food safety.
0 The public is not adequately familiar with the limitations of meat
inspection systems in detecting and removing pathogens and chemical
residues that present risks to public health. It is unrealistic to believe
every carcass can be tested for all microorganisms that are pathogenic
in humans and all potentially toxic chemical residues.
A well-designed and comprehensive program based on principles of
the Hazard Analysis Critical Control Point (HACCP) systems can
reduce or even eliminate many risks. But the public should
understand clearly that meat products may contain pathogens that can
cause disease in humans if not handled properly through production,
processing, distribution, retailing, storage, and preparation.
o
o
Effective detection and control of residues (and possibly pathogens)
will require the development of a practical cost-effective animal
identification system to permit traceback to possible sources of
residues or contamination. This technology is under development but
needs considerable perfecting before it can be applied routinely.
The quantitative data base in the peer-reviewed scientific literature is
not sufficient to support a rational public debate about meat safety or
the advantages and disadvantages of existing and proposed inspection
systems.
o For more than 80 years, FSIS has developed in its inspectorate a
strong culture of determination and responsibility for final decisions
Traditional inspection requires USDA inspectors to examine organoleptically each
carcass and viscera as they move separately through plants. In traditional inspection,
inspectors seek visible disease lesions, defects, and nonconformances (see Chapter 3),
conduct a final inspection before carcasses enter the washer or cooler, and have
authority for final disposition by declaring each carcass as passed, or condemned, or by
requiring rework (trimming) under supervision of an inspector.
Hazard Analysis Critical Control Point (HACCP) system consists of (1) an
assessment of hazards associated with growing, harvesting, processing/manufacturing,
distribution/marketing, preparation, and/or use of a given raw material or food product;
(2) determination of critical control points required to control any identified hazard(s);
and (3) establishment of procedures to monitor critical control points. Basically the
HACCP system provides a more specific and central approach to the control of
microbiological hazards than that achievable by traditional inspection and quality
control procedures (WHO' 1980) (see Chapter 2).
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o
o
on carcass disposition and dressing standards. Under STS-C,4
inspectors learned that some of those decisions had become the
responsibility of plant employees who were untrained in meat
inspection.
FSIS has not persuaded all its inspectors that SIS-C is an
improvement over traditional inspection. Objectors are concerned
about possible declines in meat safety and an increase in the
incidence of foodborne diseases due to reduction of inspector
authority and control and the introduction of statistical sampling.
Statistical sampling methods can be used to estimate the occurrence
of detectable defects. If the point in the process at which these
defects are likely to occur is known, then statistically based monitoring
can trigger corrective actions. Cumulative Sum (CUSUM), the
statistical basis for SIS-C, is a means of checking the process to
ensure that processing modifications, inadvertent mistakes, and poor
training do not cause an upward trend in defects over time.
However, CUSUM, or other statistical sampling procedures, have
limitations when they are used to assess processes applied to products
that are not uniform, i.e., that are made from heterogeneous raw
materials that contain many defects. They do not ensure that the
product is free from defects and are inadequate to ensure that no
contaminated or defective meat reaches the consumer. This
distinction seems to be the source of considerable misunderstanding.
Committee Charge, Its Response, and Its Conclusions
The committee was charged with examining five major issues. These are listed
below along with the committee's response and conclusions, where applicable.
4In Streamlined Inspection System for Cattle (SIS-C), some cuts and organ
positioning formerly done by FSIS inspectors are carried out by plant employees, the
viscera and carcass inspection stations are combined, and inspection is completed at the
viscera inspection belt. In SIS-C, every carcass, viscera, and head receives individual
FSIS inspection. However, some specific inspection procedures are omitted and
establishment employees remove designated trimmable conditions and dressing
nonconformances (see Chapter 3) without FSIS supervision. In SIS-C, inspectors
monitor finished products by examining results of the establishment's statistical analysis
of a small random sample of carcasses and by-products and by conducting additional
testing of their own.
3
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1. Evaluate SIS-C as it compares to the traditional cattle inspection system and its
acceptability as an alternative to traditional cattle slaughter inspection.
After completing its evaluation, the committee drew the following
conclusions:
Traditional inspection, SIS-C, or SIS-C with a partial quality control
(PQC)s program (SIS-C/PQC)6 are not designed to detect or
eliminate microbial or chemical hazards presented by meat products.
No data have been published to allow a determination of the relative
merits of each system in improving meat safety.
When quality control programs are effectively implemented, SIS-
C/PQC is acceptable as an alternative to traditional cattle slaughter
inspection.
o
o
o
o
FSIS should adopt with modifications the proposed rule that appeared
in the Federal Reg~ster on November 30, 1988 (see Appendix A). SIS-
C/PQC should be implemented in plants with demonstrated ability to
conduct effective quality control programs.
SIS-C without PQC should be permitted only for periods of less than
~ year in plants undergoing transition from traditional inspection to
SIS-C/PQC. There is no logical basis for making PQC optional for
plants with lower speeds.
From a food safety viewpoint, SIS-C alone is probably no better, and
in some situations can be less effective, than traditional inspection
because the reduced oversight by government inspectors is not
compensated by a total commitment to product quality on the part of
industry.
SIS-C/PQC is the most important change in bovine meat inspection
Partial Quality Control (PQC) programs involve identifying points in the process
(critical control points) that are critical to finished product standards, setting
operational standards at each critical control point, defining and documenting checks on
critical control points, and stating required action where standards are unmet. The
PQC is designed by plant management, customized for each establishment and
monitored by FSIS. PQC programs are required of SIS-C plants slaughtering more
than 275 cattle per hour.
6Streamlined Inspection System for Cat`:le/Partial Quality Control (S S-C/PQCJ is an
STS-C program in conjunction with PQC. In the proposed rule, this combination is
optional for establishments with slaughter rates of 275 or less cattle per hour.
4
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since 1906. For this system to work in practice, both FSIS and
industry must fully endorse the philosophy of shifting responsibility for
meat quality from FSIS to industry so that the government can
concentrate its resources on safety.
2. Perform on-site review of two cattle slaughtering establishments operating under
. , _
traditional inspection and two operating as pilot plants for SIS-C.
The committee visited two traditional and three SIS-C plants, two of which were
operating under SIS-C/PQC. Since it was not possible to conduct surprise inspections,
the committee assumed that the plants were operating under optimal conditions at the
time of the visits. Sufficient observations were made by the committee to give it a full
understanding of the theory and practice of traditional and SIS-C inspection.
3.
Survey procedures for monitoring pathogens and chemicals in carcasses.
Under most systems of cattle inspection, FSIS monitoring of pathogens and
chemical residues in carcasses produces archival and trend data. It is not designed to
prevent public exposure or eliminate these risks to public health. Protecting consumers
from exposure to foodborne health hazards is a complex and almost overwhelming
challenge requiring comprehensive HACCP programs (see Chapter 2) and earnest
interagency coordination7 (NRC 1985b, 1987a). Thus far, however, FSIS efforts to
improve interagency relations have not had an impact on SIS-C. Some segments of
industry are ahead of FSIS in reducing microbial and chemical risks through HACCP-
like approaches (see Chapter 5).
FSIS must support the research needed to determine how inspection techniques
can be improved to reduce levels of microbial and chemical contaminants and must
develop monitoring technology that protects consumers from potentially harmful
exposures.
4. Examine how previous Food and Nutrition Board recommendations have been
.
integrated into SIS-C.
In light of the focus and goals declared for the FSIS in the l990s (Crawford,
1990; Smith, 1990), it is unfortunate that FSIS has not integrated more of the
recommendations in previous Food and Nutrition Board reports (NRC, 1985a, 1987a)
into SIS-C (see Chapter 6~.
7Coordination among state and federal agencies and institutions that conduct
educational or regulatory programs affecting production, processing, distribution,
preparation, and serving of foods of animal origin. These include the Food and Drug
Administration (FDA), the Animal and Plant Health Inspection Service (APHIS), the
Centers for Disease Control (CDC), the Extension Service, state departments of
agricultures universities' and others.
s
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5. Evaluate the efficacy of STS-C in protecting public health.
~ _ _
Traditional inspection, SIS-C, and STS-C/PQC focus on quality; they are not
designed to address major current public health concerns (i.e., safety). Preventing
carcass contamination through increased attention to critical control points, as outlined
in company PQC programs for slaughter and dressing processes, probably benefits
public health. However, there are no published data on which to base any conclusions.
In its study, the committee found that public expectations surpass the capability
of current meat inspection laws and procedures and possibly the Congressional
mandate to FSIS. A comprehensive reevaluation of inspection programs and health
risks from the producer to the consumer is essential to protect the public from health
risks prevalent in modern production, marketing, and food preparation systems. To
this end, the committee offers the following observations on meat inspection systems:
o
o
Traditional meat inspection, relying on organoleptic examinations, can
ensure satisfactory meat product quality but is not fully effective in
protecting the public against foodborne health hazards not detectable
with these techniques. Therefore, this type of meat inspection should
not be regarded as the gold standard against which other proposed
inspection systems or new technologies for food safety are judged.
The desired characteristics of the final product should determine the
ideal standards for inspection systems. Desired attributes of meat and
meat products include both safety and quality issues, which are not
exclusive (see Chapter 3~.
Recommendations
If the role of FSTS is to establish policies and regulations based on the best
possible science to protect public health and to foster public confidence in the safety of
meat and meat products, the committee recommends that the following steps be taken:
o
o
The Secretary of Agriculture should enlist the assistance of the
Agricultural Research Service (ARS), the Cooperative State Research
Service (CSRS), universities, other research institutions, and private
industry in FSTS's efforts to develop and implement scientifically and
statistically based methods of evaluating the public health aspects of
existing and proposed inspection programs. Additional resources are
needed for epidemiologic and food safety research to support well-
designed HACCP-based food safety programs.
The federal government should design its inspection programs to
focus on contemporary public health issues. It should insist that
industry comply with policies and procedures required to protect
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public health and foster public confidence in the safety of the food
supply.
o
o
o
o
o
STS-C/PQC should be implemented in slaughter operations that
demonstrate management and employee commitment to effective
PQC programs.
FSTS should establish mandatory finished product standards and
enhance its procedures under traditional systems to extend the
benefits of PQC to all cattle, including veal calves and cull dairy cows,
that pose the greatest risks from microbial/chemical contamination.
FSIS should improve communications with its field inspectors to
ensure that they share and concur with agency goals and philosophies
of food safety in the twenty-first century.
The strength and sincerity of inspector concerns must send a clear
signal to FSIS. if the agency is to achieve its ambitious goals for the
next decade, it must learn from the STS-C experience that it is
imperative to involve its field employees in development and
implementation of new procedures.
USDA, other agencies, and industry should foster and promote food
safety education for the public. The public must understand the
potential for contamination of meat and meat products by human
pathogens and should learn safe food handling practices.
7
Representative terms from entire chapter:
critical control
