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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. 1
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). 2
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
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
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
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 6
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
