Click for next page ( 49


The National Academies | 500 Fifth St. N.W. | Washington, D.C. 20001
Copyright © National Academy of Sciences. All rights reserved.
Terms of Use and Privacy Statement



Below are the first 10 and last 10 pages of uncorrected machine-read text (when available) of this chapter, followed by the top 30 algorithmically extracted key phrases from the chapter as a whole.
Intended to provide our own search engines and external engines with highly rich, chapter-representative searchable text on the opening pages of each chapter. Because it is UNCORRECTED material, please consider the following text as a useful but insufficient proxy for the authoritative book pages.

Do not use for reproduction, copying, pasting, or reading; exclusively for search engines.

OCR for page 48
6 The Extent to Which Previous FNB Recommendations Have Been Integrated into the SIS Proposed Rule Abstract Four of the modifications made in traditional cattle inspection to produce SIS-C are in accord with previous Food and Nutrition Board recommendations (NRC, 1985a, 1987a). These are: o FSIS inspection resources have been shifted to emphasize detection of lesions rather than dressing defects. o Partial Quality Control (PQC) programs have been designed and implemented by management of some pilot plants. o Concepts of sampling and process control have been introduced. O Quantifiable data on macroscopic defects are generated, and inspection can be intensified in accordance with those data. A start has been made to address some earlier Food and Nutrition Board recommendations. For example, technical expertise is being acquired by the FSIS in pathology, microbiology, toxicology, and epidemiology, from within the agency and outside. However, progress in implementing these recommendations is difficult because of limited funding. Liaisons with other agencies and advisory bodies have not yet had an impact on plants under traditional inspection or under SIS-C. Development and utilization of rapid tests to detect microbiologic contaminants and chemical residues have been very slow. There is no visible progress in responding to many of the other Food and Nutrition Board recommendations in earlier reports. SIS-C was not intended to provide greater public health protection. Thus, improvement in eliminating unseen hazards is incidental. No steps have been taken to improve the identification and traceback of fed cattle, and few efforts have been made to improve the analysis of specific diagnoses and to relate them to animal husbandry practices. The committee was charged with examining how SIS-C integrated previous Food and Nutrition Board (FNB) recommendations, specifically those in Meat and Poultry Inspection: The Scientific Basis for the Nation's Program (NRC, 19SSa) and Poultry Inspection: 77`e Basis for a Risk-Assessment Approach (NRC, 1987a). Although SIS-C was designed and implemented in pilot projects before the release of those reports, it partially addresses some of their recommendations. It should be made clear that SIS- C was not intended to be an FSIS response to the previous FNB reports. However, the committee was charged with examining the degree to which SIS-C integrated 48

OCR for page 48
previous recommendations into the proposed rule. During the course of its study, the committee studied the previous FNB reports, observed what portions of them had evidently been adopted in the plants visited, read FSTS printed responses to the FNB reports (FSIS 1986, 199Oc), queried USDA officials verbally, and studied FSIS written responses to a request for an accounting of the relationship of STS-C to each recommendation in the 1985 report (see Appendix B). The committee did not undertake a reexamination of all the issues and recommendations raised in the earlier reports. It chose to comment briefly rather than present a detailed chronicle identifying every minor action of FSIS in response to earlier recommendations, and to address only those issues that we included in SIS-C and only those covered in the references provided to the committee by FSTS (FSIS, 1986, 199Oc). In the following paragraphs, each recommendation of the previous committees is paraphrased and followed by the comments of the present committee on the degree of integration. Recommendations in Meat and Poultry Inspection: Me Scientific Baszs of the Nation's Program (NRC, 19SSa) Recommendations Detection and Elimination of Pathogenic Microorganisms The committee recommended that FSIS intensity its efforts to control and eliminate contamination with microorganisms that cause disease in humans. Such efforts should include evaluation of rapid diagnostic procedures for detecting microorganisms, especially species of Salmonella and Campylobacter, and education of the general public, health care personnel, educators, and extension service workers in the safe handling of meat and poultry. The committee also recommended that meat handling practices in plants be monitored and evaluated in an attempt to prevent the occurrence of meat- and poult~y-derived infections among plant employees. Although their prevalence is low, these infections present important and avoidable occupational hazards. Better epidemiological surveillance and coordination of efforts to eradicate these diseases are also needed. Comment of the Present Committee: This recommendation has not been integrated into SIS-C, which is not designed to provide inspection procedures for the detection of invisible contamination by pathogenic microorganisms. There is no conclusive evidence that product contamination with invisible pathogenic microorganisms is either better or worse under SIS-C. 49

OCR for page 48
Preventing and Detecting Chemical Residues The committee recognized that the National Residue Program (NRP) is constrained in many ways by its legislative mandates. It recommended, however, that the NRP strive to make substantial progress in several categories to meet the requirements of an optimal program identified by the committee. In particular, the NRP should incorporate strategies that would protect consumers from exposure to potential health hazards. One of the ways this could be accomplished is to introduce a system to identify and trace animals back to their farms. The sampling plan to test chemical residues should be revised to improve the confidence level of detection by using appropriate statistical methods and new technological advances. Furthermore, the committee suggested that FSTS reexamine the priorities and the methods used by regulatory agencies for establishing tolerance levels of chemicals to ensure that they appropriately reflect the degree of risks to public health. Formal risk assessment and frequent communication with other regulatory agencies and with scientific peer-review groups would be particularly beneficial to FSIS in this endeavor. Comment of the Present Committee: Comments on this recommendation will be found below among those in the section on "Characteristics of an Optimal Meat and Poultry Inspection Program." Monitoring Hazardous Agents During Livestock Production and Traceback Mechanisms The committee recommended that means be found for FSIS to coordinate the control and monitoring of hazardous agents during production, when those agents enter the food supply. Furthermore' it recommended that a system be developed for keeping track of food animals during their lifetime, that procedures be instituted to trace residues in samples back to their sources, and that a national center be established to monitor and store information on animal diseases. To assist in these efforts, the committee recommended that all USDA animal disease surveillance programs be designed and implemented to use fully the animal disease prevalence data obtained from meat and poultIy inspection programs. Comment of the Present Committee: The design of the SIS-C inspection program does not incorporate this recommendation in whole or in part. Integration of Risk Assessment Procedures into the Inspection Process _ . ~ Overall, the committee recommended that the precepts of risk assessment (identification of the problem, exposure assessment, hazard assessment, and quantitative health risk assessment) be systematically embodied in the planning and evaluation of all phases of meat and poultry inspection, and that risk-assessment criteria be used regularly to assess consequences to public health resulting from any modifications to the inspection process. 50

OCR for page 48
Comment of the Present Committee: The design of SIS-C did not include the principle of risk assessment in whole or in part. There is no evidence that STS-C confers greater benefit to public health than traditional inspection. Research and Advisory Programs to Develop High Technolo~-Based Inspection. In the judgment of the 1985 committee, the techniques that have the greatest potential applicability to FSIS procedures are imaging techniques, computer-assisted information transfer, and automated laboratory methods for analysis and measurement. To achieve the goal of installing a modern, technology-based system, the committee recommended that FSIS develop a capability for conducting or contracting for scientific and technical research tailored to its needs, rather than depending on other USDA agencies. However, interaction with other USDA and other government agencies as well as private groups is essential. Thus, the committee also recommended the establishment of a scientific advisory body composed of representatives from government, industry, universities, and research organizations to facilitate such interaction. Comment of the Present Committee: In the data reviewed, the committee found no evidence that SIS-C incorporates this recommendation in whole or part. However, FSIS has proceeded slowly to pursue some of these recommendations by using some new tests in the inspection of swine and nonfed cattle. Also, FSIS has developed a National Advisory Committee on Microbiological Evaluation of Foods. Characteristics of an Optimal Meat and Poultry Inspection Program The 1985 committee identified the following components (not in any order of priority) of an optimal meat and poultry inspection system. It recognized that many of these components were part of the FSIS system at the time of its review in 1985. The present committee summarized FSIS's May 1990 responses to these components (FSIS, 1990c) and added its comments: A System of Traceback to Producers 1985 Report: A trace-back and recall system from final sale to producer for all animals and products destined to enter the human food supply was recommended by the committee as an essential step for the generation of data that are important to the prevention of disease in humans and that will enable processors and the government to recognize potential hazards in the food chain (NRC, 1985b). Summary of FSIS's May 1990 Response: A regulation has been promulgated regarding 51

OCR for page 48
identification of swine moved interstate prior to slaughter (FSIS, 199Oc). Comments of the Present Committee: This 1985 recommendation has not been integrated into SIS-C. Use of Plant Personnel to Monitor Critical Control Points 1985 Report: The committee recommended maximum use of plant personnel in process-by-process and day-to-day monitoring of critical control points and FSIS oversight to ensure compliance. Summary of FSIS's May 1990 Response: This recommendation has been implemented. Comments of the Present Committee: The recommendation has been integrated into SIS-C. Use of Contemporary Technologic Expertise In Insnection Management 1985 Report: The 1985 committee recommended that all phases of inspection be performed by a technically qualified team with up-to-date knowledge of veterinary medicine, food science, public health, food engineering, food technology, epidemiology, pathology, toxicology, microbiology, animal science, risk analysis, systems analysis, statistics, computer science, and economics. Similarly, plant managers should have expertise in several relevant disciplines, including veterinary medicine, food science and technology, nutrition, public health, and public management. No one discipline should dominate management. Summary of FSIS's May 1990 Response: To increase its access to technical expertise, FSIS decided to recruit already trained food technologists, to educate agency personnel in inspection procedures, and to enlist the help of other specialists through contracts. To date, it has hired and trained more than 219 food technologists, has embarked on a program of training FSTS personnel as pathologists, is planning in 1990-1991 to send two employees to a university to receive training in biotechnology, and has added a basic introduction to biotechnology to the curriculum in the FSIS inspection training program at Texas A&M University. It has also convened the National Advisory Committee on Microbiological Criteria for Foods. Comments of the Present Committee: The committee recognizes that FSIS has begun to acquire needed technical expertise. However, there are very few FSIS employees with contemporary training in fields such as microbiology, toxicology, and epidemiology, 52

OCR for page 48
and few consultants are used. Multitiered Levels f Inspection 1985 Report: The 1985 report recommended an inspection system with different levels of intensity, reflecting the degree of public health risk at various stages in the process, the reliability of the monitoring system, the compliance history of the slaughterhouse or processing plant, and the special needs of the intended consumer (e.g., military personnel and schoolchildren). Summaly of FSIS's May 1990 Response: The frequency and intensity of inspection are influenced by the documented history of the plant's performance. Comments of the Present Committee: The recommendation is implemented in part under SIS-C, since the sampling scheme varies in intensity, depending on compliance, and since corrective action is possible when levels of visible contamination increase. But lowering visible contamination does not equate with lowering public health risk. The committee found no evidence that attention is paid to the special needs of the intended consumer. Analysis of the Utility of Each Inspection Procedure 1985 Report: Another 1985 recommendation was the development of a list of the diseases that can be identified by each step in the inspection procedure. This list should be used to determine whether the steps are useful for protecting human or animal health and for detecting aesthetically objectionable conditions and whether they are necessary to protect consumers against fraud or are able to provide other identifiable benefits. Summary of FSIS's May 1990 Response: FSIS has been working on the list of diseases identified by each step of the procedure. It has been collecting data on swine to correlate condemnations with specific diseases. There are plans to correlate these data with farm disease data collected by the National Animal Health Monitoring System (NAHMS) of the Animal and Plant Health Inspection Service (APHIS), to replicate the mode] for other species, and to upgrade and enhance the Animal Disease Reporting System. Comments of the Present Committee: The list recommended by the 1985 committee could be interpreted in two ways: (1) a list of specific diseases detected during the meat inspection process or (2) a list relating specific detectable diseases to each anatomic site examined in each inspection maneuver. 53

OCR for page 48
FS]S appears to have responded to the first interpretation. Except for a few diseases such as tuberculosis, actinobacillosis, and cysticercosis, data available at present give only broad general categories of the diseases of cattle that may be the reason for condemnation. This lack of information is the same under both traditional and SIS-C inspections. Progress is being made at an extremely slow rate. The present committee believes that SIS-C might have suffered less resistance from FSIS employees had the basis for such changes from the traditional system ~ e.g., deleting incision of the atIantal lymph nodes and medial masticatory muscles) been explained to them. The original set of procedures was formulated with specific diseases in mind, and it is acceptable to change procedures to reflect changes in disease prevalence over time. Develop a Data Base on Specific Causes of Condemnations 1985 Report: Random sampling of retained or condemned carcasses and parts of carcasses is needed in order to develop definitive diagnoses. These diagnoses can be used to establish baseline data on etiologies associated with each condemnation category and to provide material for pathology correlation sessions as continuing education for in-plant veterinary medical officers. Summary of FSIS's May 1990 Response: An Extension Service study (pilot program) is under way to determine if definitive diagnoses are effective in disease prevention. The success of this pilot program will determine future funding. Agency pathologists are working to improve specific disease diagnosis and are developing procedures to gather and use this information. Comments of the Present Committee: There appears to be no change under SIS-C in the establishment or use of specific disease diagnoses as a basis for upgrading inspection efficiency or for continuing education of inspectors. Rapid Screening for Residues 1985 Report: Rapid, inexpensive screening tests are needed to detect a broad array of chemical and biological contaminants that may be hazardous to the consumer. Summary of FSIS's May 1990 Response: Four tests have been developed or used by FSIS (for sulfa drugs, antibiotics). Eleven additional tests are being developed; some are undergoing field trials. A chromatography system that is durable under field conditions and a computer-assisted residue testing system are being evaluated. 54

OCR for page 48
Comments of the Present Committee: The developed tests mentioned by FSIS are used mostly on swine, veal calves, or cull cows and are not routinely implemented under SIS-C. FSIS has begun to move in the right direction by developing rapid diagnostic tests, but much more effort is needed to incorporate the latest knowledge into diagnostic capabilities and rapid residue identification. Protection f Consumers from Residues 1985 Report: l An adequate sampling plan should be designed to protect the consumer from exposure to chemicals that are not randomly distributed across the country. Summary of FSIS's May 1990 Response: The development of a data base has begun. Information will be provided on incidence of residues. It would be unrealistically expensive to change the focus from monitoring of incidence to prevention of consumer exposure. Comments of the Present Committee: Development and planning activities have not yet yielded results. The public and inspectors still hold the opinion that residue monitoring is intended to reduce public exposure and are dissatisfied because of their perception that this has not happened. Hazard Analysis Critical Control Point tHACCP) Programs 1985 Report: Emphasis should be placed on HACCP. Inspection should be limited where the historic yield of violations is low and where public health risks are negligible. Summary of FSIS's May 1990 Response: FSIS began pilot testing the HACCP principle at a poultry processing plant in Puerto Rico in conjunction with a bacterial control project. FSIS intends to issue a report. Comments of the Present Committee: There has been some change under SIS-C, especially where PQC programs are mandated. The changes relate only to the historic yield of violations and quality issues. They do not provide proactive intervention to protect the public. Documentation and Compliance Enforcement - 1985 Report: l FSIS should provide documented assurance, backed by substantial compliance 55

OCR for page 48
enforcement, of the sanitary wholesomeness of al] meat and poultry products. Summary of FSIS's May 1990 Response: Data have been generated on plant deficiencies, and corrective and preventive actions have been taken to improve sanitation. Audits of inspection effectiveness are conducted. FSIS has initiated a project to have industry take responsibility for sanitation of its plants, so that inspectors become regulators rather than quality control supervisors. Comments of the Present Committee: The committee has observed that under SIS-C, quantifiable data are being generated on the level of macroscopic defects found on the product. Enhanced Enforcement Capability 1985 Report: Enhanced enforcement capability is needed to impose a broad range of penalties upon violators, including refusal to inspect and approve their products. Summary of FSIS's May 1990 Response: FSIS initiated three programs in the last decade to enhance its enforcement capabilities. These programs are now being integrated. Under the integrated system, noncomplying plants will be subject to a series of enforcement actions that can culminate in withdrawal of inspection. At present, enforcement plan is used successfully in meat processing operations; there is a clan to harmonize slaughter operations with processing operations. Comments of the Present Committee: The committee did not look into penalties for violators under either traditional inspection or SIS-C. Improve Technologic Base of FSTS 1985 Report: Adequate resources are needed to ensure continued improvement of the technological base of FSIS, including the development of new inspection technologies to reduce cross-contamination of carcasses and more comprehensive assessment of toxicological hazards. Summary of FSIS's May 1990 Response: FSIS requested and was granted funds to support methods development. Work is being done through the Agricultural Research Service.- The methods embrace modern biotechnology. Comments of the Present Committee: Development and planning activities have not yet yielded results that are used routinely under SIS-C. 56

OCR for page 48
Mandatory Continuing Education 1985 Report: A mandatory system of initial and continuing education is needed to train inspection personnel in food science, food technology, pathology, and public health in combination with a recertification program. Summary of FSTS's May 1990 Response: FSTS had in place a mandatory system of initial and continuing education for inspection personnel at the time of the 1985 report. It trains veterinarians, food inspectors, industry personnel, and supervisors. There is a Career Development Program, which provides refresher courses. Also, it has supported training at universities in pathology and epidemiology. Comments of the Present Committee: In view of the importance of the fundamental changes in meat inspection philosophy implicit in SIS-C, FSIS could have done more to promote training of its inspectors at SIS pilot plants (see Chapter 3~. Involvement f Scientists in Policy Development 1985 Report: A large scientific and technical FSTS staff of respected scientists is needed to participate in the development of policy. Summary of FSTS's May 1990 Response: Through a newly created position at the Assistant Deputy Administrator for Science level, FSIS laboratories have become part of the decisionmaking team. The creation of the National Advisor Committee on Microbiological Criteria for Foods, which gives the agency access to scientific and technical advice, was a response to the 1985 Food and Nutrition Board recommendation. Comments of the Present Committee: The administrative changes do not seem yet to have made major differences in SIS-C plants (see Chapter 3). Expert Advisory Panels 1985 Report: Standing advisory panels composed primarily of outside experts should be established to provide consultation on both policy and practice related to meat and poultry safety. Disciplines represented on these panels should include food science and technology, computer applications, microbiology, biostatistics, epidemiology, veterinary medicine, toxicology, systems analysis, animal health, economics, marketing, nutrition, 57

OCR for page 48
and risk analysis. Again, no one discipline should dominate any panel. All major regulatory proposals should be reviewed by these standing advisory panels prior to finalization. SummaIy of FSIS's May 1990 Response: The Meat and PoultIy Inspection AdvisoIy Committee had already been convened at the time of the Food and Nutrition Board report. The Secretary of Agriculture must consult with that committee before issuing product standards and labeling requirements and on matters affecting the operation of federal and state inspection programs. The agency contracted with a pane] of outside experts in connection with the bacterial project being conducted in Puerto Rico on poultry to assess the critical control points for contamination with aerobic bacteria, including Enterobactenaceae and Salmonellae. A Residue Advisory Committee is e envlslonec ,. Comments of the Present Committee: As discussed in earlier chapters, these various advisory panels do not seem to be integrated into STS-C (see Chapter 5~. Interagency Liaison 1985 Report: Strong liaison between FSIS, CDC, the Food and Drug Administration, and relevant animal health agencies is needed at the federal, state, and local levels to ensure that no hazards are overlooked. Summary of FSIS's May 1990 Response: FSIS agreed with the FNB recommendations. A complex mosaic of interrelationships has been set up. Comments of the Present Committee: These liaisons do not seem to have made a difference yet at the level of the plant under either traditional or SIS-C procedures. Data and Information Analysis 1985 Report: A rapid, timely, and flexible system (probably computerbased) should be used extensively to acquire, transfer, analyze, and widely disseminate data related to inspection and to meatborne hazards. Summary of FSTS's May 1990 Response: Funds have been obtained, and data bases and networks are being established. Comments of the Present Committee: Data being collected seem to relate to housekeeping activities of a large regulatory organization rather than to tracking of 58

OCR for page 48
meatborne hazards. Implementation Timetable 1985 Report: The committee encouraged FSIS to compare its program with all the above criteria for an optimal meat inspection program and to establish a schedule for incorporating missing components as soon as feasible. Comments of the Present Committee: Some of these criteria for an optimal meat inspection program are included in SIS-C and SIS-C/PQC, but this inclusion was not in direct response to the 1985 report (NRC, 19SSa). In fact, as mentioned earlier, SIS-C was designed before that report was issued. Recommendations in Poultry Inspection: Tile Basis for a Risk-Assessment Approach (NRC, 1987a) Recommendations Although the recommendations in the 1987 report address poultry inspection, some are relevant to red meat inspection. As in the preceding section, the present committee provides comments as to whether the SIS-C inspection proposal integrates recommendations deemed relevant to red meat inspection. General Recommendations - 1987 Report: . FSIS should adopt the well-established precepts of risk assessment as an integral part of its strategy to identity and manage public health risks associated with poultry. The risk mode] presented in the 1987 report was recommended as a prototype that FSIS could refine by applying its extensive knowledge of the poultry system (NRC, 1987a). Comment of the Present Committee: There was no evidence to indicate that the risk model proposed in the 1987 report (NRC, 1987a) was used for SIS-C, which was designed in the early 1980s. 1987 Report: FSIS should evaluate the current inspection system by using the risk-assessment mode] proposed by the committee and on the basis of its findings, modify the system so that it more directly addresses public health concerns. 59

OCR for page 48
Comment of the Present Committee: There was no evidence to indicate that this was considered in the proposed SIS-C rule. 1987 Report: Rather than focusing on one procedure, such as bird-by-bird inspection, as the primary component of an inspection process, FSIS should direct its efforts toward the establishment of a comprehensive quality assurance program. Such a program would consist of several components, one of which might be organoleptic inspection. Comment of the Present Committee: SIS-C is an organoleptic inspection procedure, and the products are examined on a carcass-by-carcass basis. The FSIS concept of finished-product sampling and mandatory PQC programs has considerable merit and is a step toward meeting this recommendation. 1987 Report: Emphasis should be shifted from detection to prevention of problems at the earliest feasible stage in production to increase the effectiveness of poultry risk-management activities. Comment of the Present Committee: Not covered by SIS-C, although SIS-PQC has the potential to do this. Specific Recommendations 1987 Report: FSIS should attempt to ensure that all aspects of the poultry production system are included in any risk model used, even if certain areas fall within the purview of other agencies. Qualitative risk assessments should form the initial bases for planning and selecting inspection and quality assurance programs. Quantitative assessments should be used when qualitative assessments prove inadequate and when sufficient data are available. Comment of the Present Committee: Some quantitative assessments were done in establishing finished product standards for SIS-C based on visible defects found in traditional inspection when carcasses were approved for human consumption, but there were no risk assessments. 60

OCR for page 48
1987 Report: The association between microorganisms in and on poultry at slaughter and the occurrence of disease in humans is complex. Several potential sources of contamination exist throughout the poultry system. The committee recognized, therefore, that attempts to resolve this problem will be correspondingly difficult and may require collaboration with other agencies. On the basis of its review of the literature and established principles of microbiology, however, the committee recommended that certain actions--such as the follow~ng--be taken to reduce the potential for disease to be caused by poultryborne microorganisms: o The ongoing search for data on microbial risks should continue and be complemented by new research. Emphasis should be placed on the prevention of disease in humans rather than on simple control of microbial counts during slaughter and processing. O Potentially pathogenic microorganisms on poultry should be identified, the potential for exposure to an infectious dose of each pathogen should be determined, and the potential impact on public health that would result from the failure to control exposures should be evaluated. Comment of the Present Committee: These concepts were not included in criteria established for STS-C. 1987 Report . The critical control points at which known pathogenic microorganisms such as Salmonella and Campylobacter may be introduced into the poultry system should be identified and monitored, preferably as a part of a HACCP program. Comment of the Present Committee: Efforts to address critical control points are a part of the PQC portion of SIS-C/PQC. However, there is confusion between control points critical to compliance with regulations and those critical to public health. 1987 Report: - A population-based surveillance program should be established so that disease occurrence can be correlated with inspection strategies. This will require measuring the level of pathogenic microorganisms on market-ready poultry as well as establishing a system for surveillance of disease within a welI-defined population. A range of educational programs for people who raise poultry and for those who handle raw broilers in slaughterhouses, at retail, and during food preparation in the home and commercial establishments should be developed or intensified. As part 61

OCR for page 48
of this effort, poultry products should be labelled at retail to inform consumers how to handle the poultry to prevent diseases originating from microbial contaminants. The committee's major recommendations regarding chemical residues were based on its observation that important sources of residues had not been considered in the FSIS monitoring program and that priorities for risk management had not been set according to the relative magnitude of risk for known residues. If adopted by FSIS, the following recommendations should result in distinct improvements in the residue program: o Using degree of risk as a basis, FSTS should establish priorities for monitoring residues and associated activities. o Potentially hazardous chemical residues in poultry and their points of origin should be identified. O The risks associated with identified hazardous residues should be determined. O Using known risks as a basis, FSTS in collaboration with the U.S. Environmental Protection Agency (EPA) and Food and Drug Administration (FDA) should ensure that tolerance levels are set for known hazardous residues. O Control programs to monitor the entry of residues into poultry should be developed. O FSIS should determine how chemically contaminated poultry might be removed from the marketplace or production line. O FSIS should begin to lay the groundwork for shifting resources from the organoleptic inspection of each broiler chicken to a more comprehensive program with statistically based sampling as one of its primary features. This should be undertaken as a first step in modi~ing the traditional bird-by-bird inspection system. Comment of the Present Committee: The present committee concluded that the portions of the 1987 report dealing with poultry (NRC, 1987a) have application to beef slaughter and the FSIS mission. Thus, they must be considered within the present committee's charge to evaluate how SIS-C integrates recommendations in previous Food and Nutrition Board reports. The present committee knows FSIS is aware of the basic concepts implicit in these recommendations and their application to beef slaughter operations. Although FS1S officials discuss these concepts frequently and they appear in several agency publications (FSIS 1986, 199Oa, b, c), there is little evidence of substantive progress toward integrating them into STS-C. 62

OCR for page 48
1987 Report: FSIS should shift the focus of its residue program from the detection of contaminants in market-ready products to the prevention of their introduction at points as early as possible in the production process. Such a shift would necessarily extend the agency's interests to areas that are now the responsibility of other government (including state and local) agencies. FSIS should attempt to persuade such agencies that closer communication regarding poultry-associated health hazards is a matter of primary importance and that their effective control will require a concerted effort among responsible authorities. Federal government support of broiler chicken inspection and related activities should be allocated primarily according to the degree that it can contribute to reductions in public health risk. The current postmortem poultry inspection system does not address or meet this objective. Traditional poultry inspection techniques originated from the need to control diseases of poultry and to ensure a sanitary environment during slaughter. Over the past few decades, however, it has become apparent that the methods needed to detect and control poultry-associated public health threats are more complex than organoleptic inspection techniques alone can provide. Thus, the present committee- agreed with the earlier Committee on the Scientific Basis of the Nation's Meat and Poultry Inspection Program that FSIS should consider using risk-assessment techniques to manage and control poultry-associated hazards. The committee hopes that its risk assessment mode] and its discussion of some potential applications will assist FSTS in controlling poultry-related health risks and developing a quality assurance program that will lead to nutritious and increasingly safe products. Comment of the Present Committee: incorporated into SIS-C. These recommendations have not been Conclusions As a result of its analysis of the recommendations in previous Food and Nutrition Board reports and assessment of the degree of their incorporation into SIS- C, the present committee drew the following conclusions: 1. SIS-C inspection does not integrate very many of previous Food and Nutrition Board recommendations either in whole or in part. Its design predated these reports, and there is no evidence that it was redesigned to incorporate aspects of these recommendations that would have improved the public health focus of meat inspection. 2. The modifications to traditional cattle inspection that have been made to 63

OCR for page 48
produce SIS-C do introduce a number of concepts that are in line with previous recommendations. These are: o The concentration of resources for organoleptic inspection has been shifted to detection of lesions rather than to detection of dressing defects. There are, however, very little data to show that this move has either increased or decreased public health protection. Sampling and process control concepts have been introduced together with quantifiable finished product standards. This should permit ongoing accumulation of data on carcass defects. These data could be used to evaluate current procedures as a basis for decisions about changes in inspection systems. The requirement, under certain circumstances, for Partial Quality Control (PQC) programs designed and implemented by plant management is a positive step in keeping with Food and Nutrition Board recommendations. If managers in industry take initiatives to develop these programs and show commitment to safety of the product, these programs can improve public health, regardless of inspection activities. The introduction of SIS-C has been accompanied by a reduction in the number of inspection personnel assigned to these plants when compared to similar plants using traditional inspection. This presented an opportunity for FSTS to reassign the surplus inspectors within the plant to implement additional procedures in microbiological and chemical residue monitoring that hac] been identified as a component of an optimal inspection system, but this was not done. Had this occurred, FSIS might have found greater acceptance of STS-C by its field staff and produced a better program. 64