It is a challenge to select the regulatory issue for this column. There are so many issues that will impact inspected establishments over the next year. These include: the pressure to declare shiga toxin-producing E. coli other than O157:H7 as adulterants; the Food Safety and Inspection Service’s (FSIS) validation compliance guide; customer testing of products in the field, as well as customer requirements that the supplier demonstrate that the process results in safe food; recalls for Salmonella in raw ground-beef products; mandatory notification to FSIS of potentially adulterated or misbranded product in commerce; antibiotic resistance; improved foodborne outbreak investigations by the states; and the list goes on.
Fortunately, we have a limited amount of time before this next wave hits. To survive, establishments need to use this time to get ready. Here are some suggestions:
Never lose sight of the basics: Sanitation may not be directly linked to pathogens, but a sanitary plant demonstrably shows the commitment of the establishment to producing safe and wholesome product.
Make sure the process is working: Is the establishment following its procedures, including the operational parameters of any intervention, and are its procedures working as intended? In our experience, more problems have resulted from a failure to follow procedure than any other cause.
Testing: Testing provides the feedback necessary to verify the process works. That can mean testing for pathogens, where appropriate. Alternatively, there are times when it is appropriate to test for indicator organisms, such as Listeria species. Other times, establishments can test for microorganisms to demonstrate microbiological reduction. Finally, an establishment could test for physical attributes, such as product temperature after cooking or the actual pH of an acid-based intervention as applied. When testing, make sure the test is appropriate in terms of both method and sample size and, in all cases, review the results and react to the findings. An establishment is both wasting its money and exposing itself to regulatory entanglements if it fails to review and react to test results.
Stay current: The science is advancing at an ever-increasing rate. What was state of the art in 2002 may be a dinosaur today. State extension, trade associations and FSIS outreach are sources of information â€” use them.
Communications: It is important for an establishment to communicate with its suppliers and its customers on food safety. With the suppliers, an establishment needs to understand how the suppliers are controlling food safety. Likewise, the establishment needs to let its customers know the steps it is taking to provide safe product.
In the upcoming months, we will see a host of government initiatives and new customer demands. There is a small window of time to get ready. Make the most of it.
Dennis R. Johnson is a principal with Olsson Frank Weeda Terman Bode Matz PC in Washington, D.C. Mr. Johnson has 30 years experience in food-safety law and regulation, representing large and small meat and poultry companies and trade associations before USDA’s Food Safety and Inspection Service.
Get ready: Here it comes!
July 1, 2010