In finalizing its new federal standards to reduce Salmonella and Campylobacter in poultry, USDA announced that it will begin posting information online about individual companies’ food safety performance. The standards, along with the updating of the USDA FSIS microbial testing schedules at poultry facilities, are focused on raw chicken parts as well as ground chicken and turkey products. FSIS implemented new sampling procedures in January 2015 when the new standards were proposed. Routine sampling throughout the year, instead of infrequent sampling on consecutive days, was intended to more thoroughly assess whether the facility’s processes effectively addressed Salmonella and Campylo bacteria. Those sampling results will now be the basis of the online information, with the agency posting if each facility passes, meets or fails the standards, once it has completed a full set of testing under the new standards. USDA has been gradually rolling out more stringent standards for meat and poultry over the last decade to modernize its food safety inspections and lab testing, along with facility recordkeeping and product labeling. In 1996, FSIS implemented performance standards for whole chickens; and the just-released standards for ground poultry and chicken parts are based on its further learning that Salmonella levels increase as chicken is further processed. The standards are also an outcome of the 2013 Salmonella Action Plan, fulfilling the major steps that FSIS had outlined in the plan. Agriculture Secretary Tom Vilsack expects the new standards, testing and increased transparency about poultry companies’ food safety performance “to help prevent tens of thousands of foodborne illnesses every year, reaching our Healthy People 2020 goals.” Based on scientific risk assessments, FSIS estimates it could prevent 50,000 illnesses annually. If this is correct, it represents about 5% of all the estimated 1 million cases of Salmonellosis in the US on an annual basis. The FSIS pathogen reduction performance standards are designed to achieve at least a 30% reduction in illnesses from Salmonella in chicken parts, ground chicken and ground turkey; 32% reduction from Campylobacter chicken parts and ground chicken; and 19% reduction fromCampylobacter in ground turkey (for which FSIS has found the prevalence to be already low). Although these standards focus specifically on poultry, USDA has been actively taking steps to improve the safety of all meats, such as: Adopting a zero-tolerance policy for raw beef products containing six additional strains of Shiga-toxin producing E. coli. Requiring that mechanically tenderized beef products are labeled and include validated cooking instructions. Implementing a new “test and hold” policy in 2012. Working closely with FDA and CDC to collectively form the Interagency Food Safety Analytics Collaboration (IFSAC), which focuses on foodborne illness source attribution. What this means to you At first blush, this approach by FSIS could appear as a “Name and Shame” program. I am not sure if that was the intent, but I have little doubt that various organizations will be tracking and talking about this new information as it gets posted. However, whether or not your facility is USDA-regulated, I would see a key take-away from all this being that, despite its prominence in the industry, FSMA is not the be-all and end-all of food safety. FSIS can and does rattle its food safety sword, too. That is not to say, of course, that FSMA compliance is not critical and shouldn’t be a major focus of your food safety practices as the deadlines loom. But you need to ensure you are looking at all your products and ingredients, to ensure you know, meet, and preferably exceed, all the relevant standards and regulations. Many facilities process a vast of array of products using ingredients from all the food groups. This means that a facility that produces pizzas, pot pies, soups, entrees, or any other such combined-ingredient product need not only be aware of and comply with applicable FSMA Preventive Controls and Produce Safety rules, but needs to know and follow USDA’s meat and poultry regulations – and/or ensure your suppliers are doing so. And don’t forget about foreign suppliers! The food supply chain, and its vast array of standards and regulations, has always been complex. But will we see a similar trend out of FDA to be more public about the data they collect? The obvious example would be for FDA to publish a redacted version of its 483 standards. I suspect there are those at FDA who would really like to do that – but I don’t think it will happen in the near future. But today (to jump back to the title and opening sentence of this newsletter) the demand for transparency – as illustrated by USDA’s decision to post inspection results on the web, means that the success of your product and the protection of your reputation is not only dependent on doing things the right way, but also on letting your consumers know – and see – exactly how you are doing that. Stay tuned for next week’s newsletter, when we delve further into that very topic. Poultry Facilities’ Food Safety Performance to be Posted Online – Will this Create Reputational Risks? by David Acheson is licensed under a Creative Commons Attribution-ShareAlike 4.0 International License. About The Acheson Group (TAG) Led by Former FDA Associate Commissioner for Foods Dr. David Acheson, TAG is a food safety consulting group that provides guidance and expertise worldwide for companies throughout the food supply chain. With in-depth industry knowledge combined with real-world experience, TAG’s team of food safety experts help companies more effectively mitigate risk, improve operational efficiencies, and ensure regulatory and standards compliance. www.AchesonGroup.com
