Industry and consumer groups, as well as the government, have sharpened their focus on keeping E. coli-contaminated meat out of the supply chain.
That's not to say any big changes have been made yet, but the spotlight has been trained on the issue, and more sectors are making themselves heard.
The U.S. Department of Agriculture's Food Safety Inspection Service held two public hearings — one in the spring and one in the fall — specifically on E. coli 0157:H7 contamination of meat, and the recalls resulting from it. The reaction: reams of comment from ranchers, meat processors, grocery distributors, former government officials, union members and consumer groups, many of whom argued that current Hazard Analysis and Critical Control Point protocols are not working properly to prevent contamination at slaughter sites.
“It is a grave concern for the public and for our member retail outlets, who will feel the brunt of the damage and/or death, which HACCP's ‘hands off’ policy will cause,” said McKee Anderson, president, Montana Food Distributors Association, Helena, Mont.
Anderson referred to what some say amounts to deregulation of the meat industry with the inception of HACCP.
“During the USDA'S initial rollout of the HACCP ideals to the industry in 1995 and 1996,” Anderson said, “some of the agency's descriptions of HACCP to the industry included:
“(1) Under HACCP, FSIS would assume a ‘hands off’ role. (2) Under HACCP, FSIS would no longer police the industry, but the industry would have to police itself. (3) Under HACCP, FSIS would disband its previous command and control authority.”
Anderson said he believes the system breaks down at the slaughterhouse and that there should be more government oversight at that point.
But the National Meat Association, Oakland, Calif., takes a different position, saying that, for the most part, systems are working as they should at the slaughter sites.
In fact, NMA government relations director Jeremy Russell emphasized that the government does oversee plant operations.
“HACCP hardly involves slaughter plants policing themselves,” Russell told SN. “The U.S. still operates under a Federal Meat Inspection Act. There are inspectors in every plant, every day.”
Like other industry sources, Russell agreed that prevention is ideal, thus preventing the necessity for recalls and tracebacks.
“When livestock arrive at slaughter, every animal is examined by a USDA vet, who has the responsibility to assure the animal is fit for the food supply,” Russell said. “When livestock are approved for slaughter, packers have the responsibility to maintain operational standards and apply microbial interventions. They do so under the watchful eye of government inspection,” he added.
Russell pointed out that further processors must also maintain product integrity. The cold chain must be maintained throughout storage and transport. And retailers and restaurants have their respective responsibilities as well. “All in order to prevent illness,” he said.
Certainly, other sources say, the cold chain needs to be kept, and all segments of the supply chain must tend to their responsibilities, but they point out that E. coli is an enteric bacterium and thus logically contaminates the meat at the killing site.
That is what John Munsell, manager, Foundation for Accountability in Regulatory Enforcement, Miles City, Mont., has been saying for quite a while.
Munsell, a former owner of a further processing/grinding plant, has authored a traceback bill that calls for fast traceback, in the event of a recall, to the point of slaughter. He also maintains that problems start at many slaughterhouses because they essentially are unregulated.
Ranchers agree.
In addition to supporting traceback to the slaughterhouses, members of Ranchers-Cattlemen Action Legal Fund, United Stockgrowers of America (R-CALF USA), Billings, Mont., a nonprofit organization of cattle producers with 12,000 members in 47 states, contend the problem begins at the killing site.
“We need Congress to reform an obviously failed system of self-inspection under the HACCP program,” R-CALF USA Chief Executive Officer Bill Bullard said last spring.
“What appears to happen under this failed system is that the small- to medium-sized packers are the ones that feel the brunt, and we see them exit the industry,” he said. “[Cattle producers] need more, not less, packers to sell their cattle to.”
In letters sent to Sen. Max Baucus, D-Mont., Sen. Jon Tester, D-Mont., and Rep. Dennis Rehberg, R-Mont., officials at R-CALF USA said the organization supports the proposed traceback bill written by Munsell.
Last week, Shae Dodson, R-CALF USA's communications coordinator, told SN the organization continues to support the proposed traceback bill.
In fact, Dodson said, the issue of E. coli contamination will most likely be discussed at the organization's upcoming convention, Jan. 23 and 24, in Rapid City, S.D. “Our HACCP committee will be giving a report, and also individual members can suggest policy,” she said.
In their presentations at the USDA/FSIS public meetings, several industry sources — in addition to consumer groups — stated that the source of E. coli contamination is logically at the point of slaughter, and many suggested tighter controls at slaughter plants, including changes in sampling procedures.
They also said that even if FSIS guidelines cover all bases in writing, they are not always adequately communicated to on-site inspectors.
One man, who represents a union of government employees, sees the whole scene in the meat supply chain as part of a larger deregulation effort.
“I've told the Obama transition team that the agency has got to get back into a regulatory mode in order to protect the consumer,” said Stan Painter, chairman of the National Joint Council of Food Inspection Local Unions, American Federation of Government Employees, and a current employee in the Jackson, Miss., FSIS district.
Painter, who filed testimony at the FSIS meeting, is one of the industry sources who is critical of the way HACCP is used at the slaughterhouse level. He told SN it just is not working as it was intended to.
“I think HACCP has been the biggest failure this agency has ever created,” Painter said.
On government oversight, he is particularly critical. He said inspectors are told [by FSIS] not to put particular violations in their reports. They're told, he said, that they should lay back and see if proper action is taken later.
“The problem is, we're there for a very short period of time. We're encouraged to not write noncompliance reports,” Painter told SN.
When inspectors have filed noncompliance reports, FSIS often says they acted too quickly, Painter said. The theory is that the matter will be taken care of by plant management. It often is not, according to Painter.
“I've seen inspectors eager to retire as soon as they can because they're so frustrated by the policy.”
There is too much territory for inspectors to cover, Painter pointed out.
“We're just in the door and out and have to go on to the next location. We should go back to just five district offices. With rent money saved, FSIS could fill the positions that are open.”
Painter seconded Munsell's statement that “HACCP is broken” at the slaughter plants, even though the concept was a good one, he said.
“I've seen some plants start out with 11 critical control points, and then bring it down to one or two when they see they don't have to do more.”
All participants in the FSIS meetings agreed that intervention at slaughterhouses is necessary, and many participants proposed a sharper focus on sampling trim, thus catching the contamination before it gets further along the supply chain.
“FSIS should put emphasis on trim testing, not ground [beef]. Process control begins on the slaughter floor, the ultimate source,” said Barbara Masters, a former FSIS administrator and now senior policy advisor at Olsson, Frank & Weeda, a Washington, D.C., law firm.
Masters gave a slide presentation on behalf of Olsson, Frank & Weeda at the October FSIS public hearing in Washington.
She urged that in addition to multiple positives triggering a review of practices at the source, a continuing absence of positives should also be a red flag.
“The virtual absence of positives should trigger a review by FSIS as to the adequacy of sampling and/or laboratory methods,” Masters said in her presentation.
“I truly believe companies, including the slaughterhouses, whether large or small, try to do the right thing, but we can take learnings from what happens,” Masters told SN.
“There could be a sufficient number of inspectors and enough interventions, but they [interventions and sampling] may not be being carried out correctly. Are they using the right test kit? Is the sample being taken from the surface [where the contamination, if there, logically would be found]?”
Speaking on behalf of consumers, Felicia Nestor, senior policy analyst at Food & Water Watch, also gave a slide presentation at the fall FSIS meeting that dovetailed with comments Munsell has filed with USDA and with his congressmen. In fact, much of what Nestor said is also stated in Munsell's proposed traceback bill.
At the meeting, Nestor called for traceback all the way to the source of contamination: the slaughterhouse.
She said FSIS' enforcement efforts up to this point have been almost entirely at the end of the line, at small grinders and small plants.
“As a result, since 2003, more than 40% of very small grinders have stopped producing ground beef,” Nestor's slide presentation showed.
“At the same time, FSIS avoided identification of plants that could have been the source of the problem, particularly large slaughter plants,” she said.
Meanwhile, the American Meat Institute, Washington, filed comments with FSIS after the meeting that, among other things, called for a sharper focus on trim testing at the point of slaughter.
“We believe that's more valuable than testing ground beef,” said Scott Goltry, vice president, food safety and inspection services, at AMI. “It's less disruptive in the supply line, and isolates the problem.”
Goltry also told SN he recommended that FSIS re-evaluate its goals to put them in line with new methodology.
Jim Hodges, AMI's executive vice president, said AMI's position has consistently been to encourage testing of trim.
“The focus should be on the parts, not on the ground beef. It makes better sense,” Hodges said.
USDA/FSIS is currently reviewing presentations made at the public meeting and comments that were filed afterward. The agency received comments from the industry and the public up to Dec. 17.
“The October meeting provided a good exchange of information and suggestions, from both industry and consumer groups, that will be considered as we continue to work with stakeholders,” Amanda Eamich, senior press officer, USDA/FSIS, said earlier this month.
