USDA Reform Targets Food Safety
By Susan English
Washington, D.C.–The USDA`s Food Safety and Inspection Service (FSIS) is instituting a new food safety assurance program based on the implementation of Hazard Analysis Critical Control Points (HACCP). The FSIS is responding to new food processing and packaging technologies, and most importantly, the appearance of new microbial pathogens that have long-term complications.
HACCP is a science-based regulatory performance standard in meat and poultry slaughter and processing plants, and it mandates three near-term interventions that address plant sanitation, antimicrobial treatments, and carcass chilling. The goal of the proposed new program, the “Pathogen Reduction/ HACCP” rule, is to implement an integrated, HACCP-based inspection system approach, maintaining the distinction between industry and FSIS responsibilities, and targeting the most significant hazards, while at the same time, fostering “flexibility, innovation and accountability for improving food safety.”
Responding to popular, political, and industry-wide pressure to resist further “regulation,” FSIS recognizes that to achieve its goals, it must also streamline current regulations and eliminate unnecessary and redundant regulations. According to the FSIS, the movement to a HACCP work environment would represent “the most significant change to the regulatory process in the history of the inspection program,” a shift from inspection to prevention.
The new focus will mark a shift from prescriptive “command and control” requirements to greater use of performance standards–mandating standards, but allowing food processing companies the flexibility to innovate more efficient methods for meeting their food safety responsibilities. Thus, under the proposed rule, industry would assume full responsibility for production decisions and their execution, while the FSIS would monitor and enforce plants` compliance with food safety standards and verify process control.
Performance Standards
The current regulations for the production of cooked beef products, uncured meat patties, and certain poultry products call for a precise sequence of steps to produce safe food. FSIS is proposing performance standards to supplement the current regulations governing the production of these products to provide industry with more flexibility in determining processing procedures, while maintaining the same high standards for food safety. The proposed performance standards spell out the objective level of performance that plants must meet during their operations to produce safe products, allowing the use of processing procedures other than those prescribed in current regulations.
Industry Process Control
FSIS inspectors will play an increasingly active role in implementing the HACCP requirements, specifically in the areas of record review, visual process verification, and product sampling. Inspection roles and responsibilities would shift from detecting facility and production problems to validating and verifying that plants are producing safe meat and poultry products that meet the newly established requirements.
Eliminating “Prior Approval” Requirements
The Agency`s “prior approval” systems are being overhauled, with many requirements for prior approval of plant drawings and specifications, as well as equipment, scheduled to be eliminated. The FSIS proposes to do away with most plant-operated quality control programs prior-approval requirements to encourage the industry to take more control of its own safety assurance processes. Under the current proposal, “substances approved for use in the preparation of meat and poultry products,” the FSIS would no longer issue its own regulations listing substances it finds suitable for use in meat and poultry products, but would rely on the FDA to specify in future regulations whether a substance could be used in or on meat or poultry products.
Identity Standards
To encourage the production of processed meat and poultry products with reduced levels of fat, cholesterol, and sodium, the FSIS will propose to permit manufacturers, “under certain conditions,” to deviate from the standard of identity, while still using the traditional standardized name. For example, a “low-fat frankfurter” that might exceed current requirements for added substances such as water and binders would be allowed as an exception in order to reduce the fat content.
Beyond HACCP
In addition to HACCP, along the farm-to-table continuum, the USDA is suggesting opportunities for federal, state, and local government regulators to shoulder some of the burden of standard-making and enforcement to reduce the possibilities for product adulteration and the foodborne illnesses that follow in its wake.
In the retail and restaurant sector, however, FSIS would continue its ongoing, direct regulatory authority over adulterated and misbranded product. For animal production, producer associations could promote the development of quality assurance programs that focus on risk reduction strategies for pathogen control in live animals.
The FSIS also cites the need for “further research by government, industry, and the scientific community” to acquire information about pathogen colonization in designing effective intervention programs. For transportation and storage, industry associations could promote special systems for handling meat and poultry that ensure minimal growth of pathogenic organisms. Also, the development of Good Manufacturing Practices (GMPs) to address sanitation and temperature control problems, including periodic reviews to determine rates of industry compliance, are envisioned as an alternative.
The FSIS would expand its support to state and local inspection and enforcement agencies by supporting the development and adoption of model food codes, helping state and local enforcement to standardize their protocols in concert with the Food Code; and evaluate state and local food regulatory agency inspection and enforcement programs for meat and poultry processing and handling. In the area of food handler and consumer education, FSIS would continue its current program and seek to expand its collaboration with “all interested parties” in government, industry and other private organizations to foster the effective delivery of safe-handling messages to consumers in a manner that would improve safe food-handling practices.
FSIS Future Strategy
In addition to the proposed changes for meat and poultry plants, FSIS is also taking steps to prevent hazards and reduce the risk of foodborne illness throughout the chain of production, processing, distribution, sale, and handling by food preparers.
On August 11, FSIS reopened the comment period on the HACCP proposal to permit additional comment and dialogue on issues raised during the initial comment period. FSIS intends to publish a final rule after the comment period closes on October 31 and the comments have been considered. On August 23, the USDA held a public “scoping session” to discuss the agenda and format for the series of issue-focused public meetings held September 13-15 and 27-29 on HACCP.