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8 Overall Findings and Recommendations
Pages 248-272

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From page 248...
... Although most issues regarding policy were intentionally excluded from the individual commodity discussions, the committee considered some policy issues closely related to the success of scientific criteria. Thus, the committee concluded that the authority of regulatory agencies to enact and enforce food safety criteria within the current regulatory system, and the effectiveness and consistency of such enforcement, were inextricably linked to its charge and needed consideration.
From page 249...
... Furthermore, the committee concluded that the current process to modify existing food safety criteria is too rigid to allow appropriate and timely updating of these regulations to keep up with the fast pace of scientific and technological progress. · Congress should give the regulatory agencies the flexibility needed within the administrative process to update food safety criteria, including performance standards, so that new scientific knowledge and technological innovation can be timely incorporated in an efficient manner into these regulations.
From page 250...
... . Congress should require the development of a comprehensive national plan to harmonize the foodborne disease surveillance that is conducted by public health agencies with the monitoring of pathogens across the food production, processing, and distribution continuum that is conducted by food safety regulatory agencies, and allocate the funds to develop and implement this plan.
From page 251...
... HACCP The committee concluded that the positive balance of progress in food safety after implementation of HACCP, as measured by overall reductions in several major foodborne diseases, is a tribute to the efforts of industry and the regulatory agencies to improve food safety. This progress confirms the committee's belief that industry and food safety regulatory agencies alike must continue to focus on prevention, reduction, or elimination of foodborne hazards along the food continuum through a science-based food safety assurance system.
From page 252...
... Strategies for Developing Science-Based Food Safety Criteria Regarding the strategies available to the regulatory agencies to develop science-based food safety criteria, the committee concludes that it is seldom possible for regulators to base new regulations strictly on laboratory data or using only expert opinion. · Recognizing that it is impossible to fill all data gaps, the committee recommends that regulatory agencies use a strategy that combines the use of the best available data and the best expert judgment as an appropriate, science-based means to establish food safety regulations.
From page 253...
... Similarly, for flexibility, the committee recommends that the regulatory agencies periodically evaluate and update food safety criteria. To this end, Congress should enable regulatory agencies to incorporate flexibility into the administrative process, so that these criteria can be adjusted efficiently to meet future public health goals.
From page 254...
... Microbial Risk Assessment is rapidly evolving into a major scientific methodology on which to base food safety criteria. However, the committee emphasizes that defining microbial dose-response relationships for foodborne pathogens is essential if more accurate microbial risk assessment results are desired.
From page 255...
... Conceptually, an FSO could be established on the basis of a quantitative risk assessment of the hazard of interest and would be consistent with the level of consumer protection that the regulatory agency deems appropriate to fulfill the public health objective. This concept may be useful to regulators in developing performance standards for application at the processing plant level (processing safety objective)
From page 256...
... Although end-product testing by itself does very little to improve the safety of individual batches of food, microbiological testing has an absolutely critical role to play in HACCP plan verification and verification of scientific criteria. The committee recognizes the value of SPC as a scientific method that can help the processor to improve the process and the regulator to ensure compliance with food safety criteria.
From page 257...
... SCIENTIFIC CRITERIA IN MEAT AND POULTRY, SEAFOOD, PRODUCE, AND DAIRY PRODUCTS The committee, through its two subcommittees on meat and poultry and on seafood, produce and related products, and dairy products, examined the main safety criteria, including performance standards, currently applicable to each one
From page 258...
... Safety Criteria for Meat and Poultry The Approach to Meat and Poultry Safety Under the Federal Meat Inspection Act and the Poultry Products Inspection Act, the USDA, through its Food Safety and Inspection Service (FSIS) , inspects all domestic meat and poultry to be sold in interstate commerce in the United States.
From page 259...
... Pathogen Reduction Criteria The stated purpose of the Salmonella performance standards is to promote a reduction in the levels of Salmonella on raw meat. On this basis, the committee concludes that the Salmonella performance standards are valid.
From page 260...
... The resulting data should allow a comparison of microbial serotypes in isolates from animals, humans, and foods as a means to enable regulatory and public health agencies to allocate the burden of foodborne disease to specific foods or classes of foods and thus provide a measure of the effectiveness of specific food safety criteria. The committee concludes that the Salmonella performance standard for ground products may not reflect the overall quality of the grinding operation, but rather the quality of the incoming raw materials.
From page 261...
... advise those members of the public who would prefer to minimize the risk of this product to cook irradiated and nonirradiated ground beef products to the appropriate temperature, (2) require that these products be clearly labeled with a warning of the potential for harm if not properly cooked, and (3)
From page 262...
... Sanitation Standards The committee concludes that, although described as "standards," the actual language in the sanitation regulations includes numerous references to "adequate," "preventing sources of adulteration," and "sufficient." Therefore, these regulations provide little in the way of a descriptive and objective "standard" and are better characterized as "guides." Economic Cost-Benefit of the Pathogen Reduction/HACCP Rule As mentioned earlier, the committee concludes that more research is needed before a proper cost-benefit analysis of specific food safety criteria can be isolated from the general effects of a wider regulation such as the Pathogen Reduction (PR) /HACCP rule.
From page 263...
... Safety Criteria for Seafood There are currently over 350 species of fish that are commonly consumed. This diversity is expressed as a broad spectrum of sensory attributes, product forms, and preparations that are particular to seafood.
From page 264...
... · Enhance communications to ensure awareness, understanding, and consistent application of the Guide. In addition, the committee believes that screening limited quantities of seafood products at points of entry is not consistent with the preventive concept of HACCP; hence, prevention of seafood safety hazards in imported seafood must place greater emphasis on intervention prior to shipment.
From page 265...
... All seafood safety criteria established prior to the seafood HACCP rule remain in place within the current regulatory system. Therefore, processors must produce seafood that comply with all relevant food safety criteria.
From page 266...
... The committee recognizes that to minimize foodborne disease from being transmitted through fresh produce, it is necessary to prevent initial contamination of these products and to control the potential amplification of pathogens in them throughout the production and distribution chain. Intervention strategies currently being applied in the fresh produce industry are Good Agricultural Practices in the field and packing houses and GMPs in fresh-cut operations.
From page 267...
... Pathogen Reduction Criteria in Fruit and Vegetable Juices As a consequence of foodborne disease outbreaks associated with raw juices processed at commercial facilities, FDA introduced regulations for all juices produced for inter- or intrastate sale. This regulation mandates that juice be produced under a HACCP plan having supporting GMPs and Sanitation Standard Operating Procedures.
From page 268...
... The committee also believes that the 12-D performance standard for low-acid canned food might be too stringent and thus might compromise some quality attributes of certain canned foods; therefore, it should be
From page 269...
... Environmental Protection Agency is in agreement with the committee's belief that food safety standards should be developed based on a combination of the best available science and expert opinion, and that this process should be a transparent one. Safety Criteria for Dairy Products Anecdotal observations that linked consumption of milk with the spread of disease spurred various scientists and physicians in the United States and around the world to undertake research to investigate the role of milk consumption in foodborne disease as early as the turn of the twentieth century.
From page 270...
... Adoption of performance standards for pathogen reduction, such as that proposed for cheese manufacturing, would more appropriately fit into a HACCP framework than in the dairy industry' s current regulatory system.
From page 271...
... · In addition, state and local health authorities should ban the sale of unpasteurized milk. Criteria for Control of Hazards in Cheese Current regulations state that no milk or milk products in final package form intended for direct human consumption shall enter interstate commerce unless they are manufactured from pasteurized milk or pasteurized milk ingredients, except where alternative procedures are provided for by regulation.
From page 272...
... . The committee recommends the development and implementation of a scientifically appropriate performance standard for the reduction of targeted pathogens in finished cheese products that result from the processing strategies or aging periods employed in the manufacture of the products.


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