So far, 2013 has been both a good and bad year for food safety.
The good: We have made many advances, laboratory tests are getting faster and more accurate, food-safety programs are becoming more robust, and we have learned a lot about Salmonella and are realizing the true challenge it presents.
The bad: People still get sick from pathogens and allergens; and negative consumer perception of the safety of food due to food recalls, sensationalism about GMOs, inspector furloughs, and other negative stories still dominate mainstream press coverage of the food industry.
We reviewed three principal areas to assess the State of Food Safety: recalls, regulatory trends and focus on the future.
A quick look at the recalls so far this year shows that allergen-related recalls have dominated so far. If you are undergoing a recall, there is a 44.9% chance it is related to allergens. USDA-FSIS has 52 recalls listed, and the FDA has 164 so far; of these, 22 FSIS (42.3%) recalls and 75 FDA recalls (45.7%) are related to allergens. It is worth noting that the FDA and FSIS percentages of allergen recalls are so close to each other that the issue seems to be a food-industry problem —not just a meat and poultry problem.
Based on the comments of Dr. Dan Engeljohn, assistant administrator, FSIS, in February at the NAMA conference, and the issuance of FSIS Notice 29-13, we knew that FSIS was going to focus on allergens. However, we had all hoped that allergens would have dropped off the radar of food-safety issues in meat and poultry by now; unfortunately, that has not been the case.
Instead, the indications are that the system controls concerning allergens are not as robust as everyone had hoped. In addition, the focus on allergens appears to be driving the overall increase in recalls this year.
Pathogens combined for 25% of FSIS recalls. And while there have been only 13 pathogen recalls for FSIS-regulated products so far this year, anyone will tell you that even one is too many. See the table “FSIS recalls, 2008 vs. 2013” for a comparison of recalls by cause.
FSIS continues to refine and upgrade the Public Health Information System (PHIS), which will allow FSIS to “data-mine” and then target its enforcement actions. It captures the establishment’s food-safety program as well as the results of FSIS inspections and FSAs, etc. While not yet fully functional, it will give the agency the ability to target specific plants for enforcement actions based on any number of parameters.
For example, in the Federal Register notice concerning Validation issued on May 29, 2013 (Doc No: 2013-12763), FSIS states that the EIAOs will note findings (lack of validation data) in their FSAs. This will make it very easy for FSIS to target those establishments when they do start enforcing the validation requirements. FSIS will simply run a report showing which FSAs identified a lack of data, and give its inspection teams the direction to enforce.
Before people accuse FSIS of being in cahoots with the NSA, it should be noted that FSIS has stated its intentions to collect the information all along. However it is truly amazing how much data FSIS is actually collecting on a daily basis! It includes what is being produced, how the establishment reacts when something goes wrong, what interventions are being used, etc.
FOCUS ON THE FUTURE
At last month’s Beef Safety Conference in Chicago, Al Almanza, FSIS Administrator, made it clear that Salmonella would be the focus of FSIS in the coming year. Data from the CDC reporting that Salmonella is the leading cause of the most serious foodborne illness is driving the FSIS focus.
During the discussion portion of the conference between regulators, scientists and the industry, it also was made clear that, although Listeria and E. coli rules and subsequent interventions worked very well at driving down the numbers of each pathogen, Salmonella control will be much more complex.
To give a perspective: When going after E. coli O157:H7 and Listeria monocytogenes, we focused on very specific pathogens that are introduced into food through external cross-contamination. In the case of Salmonella, however, we are focusing on more than 20 major serotypes, many of them found in internal tissue. Add to that the fact that there appear to be geographical differences in distribution and throw in antimicrobial resistance, and it becomes clear that we have a new type of fight on our hands.
Furthermore, although the legal definition of adulterant has been determined by the courts, FSIS has made it clear that it has the authority to ask for a voluntary recall, and will do so, when people are getting sick from products contaminated with Salmonella. Lastly, it will look closely at how industry is dealing with Salmonella contamination through its food-safety plans.
There have been changes already, and more are in the works as to how FSIS looks at and reacts to Salmonella.
The FSIS team also spoke on its intent to finalize validation, streamline generic labeling requirements, roll out the HAV Inspection task, and move forward with modernizing the poultry slaughter inspection system.
PHIS gives FSIS access to information about establishments that it never had before, and all of this information is now available to FSIS personnel, from the local, in-plant inspection personnel to FSIS Headquarters staff. PHIS makes it easy for FSIS to target enforcement actions. It also will allow them to go back and map how HACCP plans are changing, and what some of the common denominators are, based on the type of establishments and how they handle hazards. As it rolls out the HAV task nationwide, FSIS will have a much better picture of how establishments are reacting. We can expect FSIS to review the data and change its policies accordingly.
A single, “super” inspection agency?
Is a single food-safety agency on the horizon? With the FSMA rules, both the FDA and USDA-FSIS are coming closer together in how their regulations concerning food are written, what they enforce, and how they enforce it. Add the interstate shipping of product that is state-inspected (with FSIS oversight), the proposed new poultry inspection system, etc., and they look even more alike.
In these times of tight budgets and sequester, even those who aren’t in favor of a single food agency are starting to rethink their positions. However, with the focus of both agencies on modernizing, and given the unique regulatory and political environments in which they work, it will be several years, perhaps decades, before we see a single food-safety agency. Several other countries have combined their programs, with mixed results.
Interstate shipping program
As more state-inspected establishments get onboard with the interstate shipping program, FSIS will face challenges similar to the FDA when it contracts out its inspections to the different state programs. FSIS had the advantage of being able to learn a lot about what works and what doesn’t from the FDA when working with state organizations.
The real challenge will arise when a state-inspected product is recalled from international commerce. How will our trading partners respond, and ultimately how will FSIS and those state programs determine the difference between “same as” and “equal to” as they work together?
Dealing with data
Establishments collect a lot of data as part of their food-safety programs; however, the days of writing it down and throwing it in a file to wait for a regulator or auditor to ask for it are over. In order to stay ahead of negative trends in food safety, and to ride the wave of positive trends, managers are going to have to (1) know what data they collect, (2) know what it means and (3) use it for the future.
Oftentimes the information we need is readily available; we just don’t know how to tie it together. As an industry, we have to figure out better and less time-consuming ways of making our data work for us. New devices and systems on the horizon will give managers the tools they need to deal with the data overload we all face.
The hardest part of it all? Showing the public that there have been an estimated 69 billion pounds of meat and poultry produced so far this year with a negligible amount of issues. They do in fact enjoy the safest food in history.