Federal Agencies Map a Better System

A joint FDA/Food Safety and Inspection Service meeting late last year is one of the recent steps taken to prevent foodborne illnesses.

Food safety is getting renewed attention from Congress and the two federal agencies chiefly charged with safeguarding the nation's food supply: the Food and Drug Administration (FDA) and the Food Safety and Inspection Service (FSIS) of the USDA.

The bill sent in December to the full U.S. Senate for consideration is S. 510, the FDA Food Safety Modernization Act, which would require each food facility to identify and evaluate known or reasonably foreseeable hazards of all types—biological, chemical, physical, and radiological hazards, natural toxins, pesticides, drug residues, decomposition, parasites, allergens, and unapproved food and color additives, as well as intentionally introduced hazards—and develop a written analysis of those hazards.

In addition, facilities would have to implement what the bill calls "preventive controls." It defines these as "risk-based, reasonably appropriate procedures, practices, and processes that a person knowledgeable about the safe manufacturing, processing, packing, or holding of food would employ to significantly minimize or prevent the hazards identified under the hazard analysis . . . and that are consistent with the current scientific understanding of safe food manufacturing, processing, packing, or holding at the time of the analysis." These may include sanitation procedures for food contact surfaces and utensils; supervisor, manager, and employee hygiene training; an environmental monitoring program to verify the effectiveness of pathogen controls in processes where a food is exposed to a potential contaminant; a food allergen control program; and a recall plan.

The bill would require FDA to inspect all food facilities more oft en, including inspecting "high risk" facilities at least annually. FDA could order a mandatory recall of a food product that would cause serious adverse health consequences if the company has not voluntarily recalled it.

As the bill was being advanced out of the Senate Health, Education, Labor and Pensions Committee, Agriculture Secretary Tom Vilsack and HHS Secretary Kathleen Sebelius, who lead the parent agencies of FSIS and FDA, respectively, joined FDA and FSIS officials at a public meeting in Washington, D.C., in early December.

Vilsack and Sebelius, who co-chair the Obama administration's Food Safety Working Group, thanked the Department of Homeland Security on Dec. 9 for opening the Commercial Targeting and Analysis Center for Import Safety, which the working group had recommended. Located in Washington, the center targets imported cargo of all kinds, including food, for possible safety violations.

The larger goal of the meeting was to work out closer FDA-FSIS cooperation.

Jerold Mande, USDA deputy under secretary for food safety, opened the meeting by describing the current U.S. system for tracing food products and the difficulty of improving the systems, as the working group has recommended.

"This problem, unfortunately, is difficult," he said. "The CDC estimates that as many as 300,000 people in the U.S. are hospitalized each year from foodborne illnesses and millions become ill and don't even realize that it is connected to tainted food. While this forum will begin with product tracing as a comprehensive task that will require cooperation and commitment from both business and government to get the job done, one area that you'll be hearing a lot about is gaps at the retail level.

"Despite the dedicated efforts of food safety offi- cials across the country, our capacity to trace tainted products is seriously limited. Poor record keeping and inadequate information about food sources, ingredients or distribution—particularly at the retail level—make tracing a cumbersome process and make recalls less effective. With an effective tracing system, when an outbreak occurred—involving ground beef for example—the product that caused the outbreak would be quickly identified, as would the retail stores where consumers purchased the product. The store would have the appropriate records that show which processing establishment produced the beef used in the ground product. And then, we could perform traceback and traceforward investigations.

"By doing so, we could make consumers aware of what contaminated product to avoid or discard, and therefore control the outbreak. At the same time, our assessment of the establishment that produced the contaminated product could detect if there's a larger problem at the plant and whether this is a systemic problem and not just a local issue," Mande continued. "However, today, we often don't have all the information we need to protect public health. For example, in 2008, during an E. coli O157:H7 illness investigation in Kentucky, FSIS and our state partners found a retail firm to be a common source of ground beef eaten by those who got sick. The retailer acknowledged it produced several beef grinds, but didn't maintain grinding logs. The retailer used possibly six to nine sources of meat in producing the grinds. As a result, FSIS was unable to trace the products back to the source. If we had been able to identify the source or sources, we could have determined if other contaminated meat remained in commerce. Doing so would have prevented other consumers from getting sick, enabled us to determine whether plants were still producing contaminated product, and allowed us to verify if corrective actions were working.

"Clearly, reform is needed at the retail level, where in many cases the traceback trail ends, but where it really should begin. Many retailers don't keep records, or the records that they do keep are inadequate. Many retailers are small businesses with small staffs, so it is easy to understand why record keeping isn't a high priority. For some, it could even be considered a burden. So there clearly are challenges before us."

Mande went on to credit retailers that maintain good records. Technology and traceback models used in other parts of the world "should make this task easier," he added. "And retail is just one point in the entire system where traceback needs to be improved. Each day, FSIS and industry tests products for microbial contamination. Efforts to determine the source of positive product that an establishment produces need to be robust to prevent contaminated product from reaching consumers.

"The challenge doesn't end at our nation's borders. Nearly 3.3 billion pounds of meat and poultry are imported into the United States each year. Trade in food is critical to our diet and permits our farmers and other food producers to sell their goods abroad.

"Foodborne illness, however, does not respect national borders so we need to be looking toward a seamless tracing system that reaches throughout the nation and the world. This is no small task and will require that everyone in the food business must do their part and make traceability a priority."

This article originally appeared in the February 2010 issue of Occupational Health & Safety.

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