Editor’s note: If you had a magic wand, how would you conjure up sustainable ways to make the food supply safe? We asked several people to consider the possibilities. Here is another response, from Dr. Richard Raymond, former Undersecretary for Food Safety at the U.S. Department of Agriculture.
If I had a Food Safety Magic Wand … that would be a daunting development, so to make it less daunting and to stay more focused, I am going to assume my Magic Wand is to primarily make our meat and poultry products safer. I will let the former FDA food safety leaders pen their own cures for what ails the food safety arena that FDA has responsibility for.
But before I focus primarily on the U.S Department of Agriculture’s (USDA) responsibility for meat, poultry and egg products safety, I want to repeat, briefly, what I said in an article for Food Safety News that was posted Jan. 3, 2011, and can be read in its entirety here.
I am going to use my Magic Wand to improve food safety by using its powers to give the USDA and its Food Safety and Inspection Service (FSIS) regulatory authority over all animals and animal products, including all fish and seafood, bison, dairy products and eggs, and to give FDA regulatory authority over all canned and bottled goods, and processed entities like frozen pizzas, sandwiches and flavoring.
The meat in these proposed FDA products has already been inspected and passed. Adding pepperoni to a pizza that contains spinach, green onions, tomatoes, cheese, pepper and other products that have been linked to foodborne illnesses does not change the public health risk, nor does adding beef to the vegetables in vegetable beef soup increase risk. But these additions of meat do add cost by now requiring daily inspection of the product.
The savings produced by moving these very low risk products to the FDA could be used to increase the inspection of animals and animal products, such as eggs and oysters, that are now FDA responsibility and have been linked to foodborne illnesses by daily FSIS inspection.
The very next thing I would use my wand for is to declare whole carcass, low dose, non-penetrating irradiation to be a processing aid, not a food additive. That done, the industry can now embrace the concept, explore its applications, and over the next few years begin to significantly decrease the pathogen load on carcasses prior to the application of other processing aids down the line, greatly reducing our risks of falling ill from consuming meat.
And, since industry will now have this very important tool to help it produce a safer product, I am now going to declare all non-O157:H7 Shigatoxin producing E coli strains to be adulterants.
At the same time, I am going to take personal risk using the Wand as my protective shield and establish a tolerance level for E coli. Before you declare me clinically insane, think about the effectiveness of the current “zero tolerance” policy. It is, at this time at least, unobtainable and non-enforceable. Develop a realistic tolerance level that is reachable with today’s interventions, and then enforce it. Allow FSIS to bring action against those few plants that provide the greatest risk to the public with their product.
And speaking of plants that impose a risk, I am also waving my wand at FSIS and mandating that they do trace back to the source of contamination to the very best of their ability. For example, in the FSIS testing program for 2010, 64 ground beef samples were positive for E coli O157:H7. Of those positives, 29 were found at plants that used only outside source material and did no slaughter of their own. And, these 29 plants used only one source in the tested lot. And that same product from that source was most likely sold to other processors as well. Yet FSIS maintains that so much ground beef is a blended product from multiple sources that trace back is next to impossible. Magic Wand, fix this. Find the source and take action.
We have other products available to assist us in making our products safer, but sometimes the bureaucracy of having three agencies (Animal and Plant Health Inspection Service, FDA and FSIS) with overlapping oversight of these products produces little movement in the approval process, as we saw with the E. coli vaccine. So I will use the powers of the Wand to declare that Phage treatments are a processing aid, not a food additive, and can therefore be used on primals and trim without labeling restrictions.
Before my Magic Wand’s powers weaken, I want to accelerate the research on the efficacy of the E coli vaccines. One way I will do this is to provide tax incentives for those companies willing to spend their own resources in this effort. Heck, I think I will provide tax incentives for any research into more effective ways to produce a safer product. And then I will wave the wand again, and make FSIS a more cooperative partner with plants looking for new ways to improve safety, and become less of a hindrance to them.
Now that my wand has effectively provided me with the information to declare the E. coli vaccine to be a very effective pre-harvest tool in reducing E coli in beef, I am going to declare the pathogen to be an environmental hazard worthy of the government’s attention to reduce its presence.
Produce is accountable for 34 percent of all E. coli O157:H7 foodborne illnesses, ground beef being responsible for 33 percent, according to Robert Tauxe of the Centers for Disease Control and Prevention. One-third of E. coli illnesses are not even related to food, but come from our drinking water, recreational water, petting zoos and person-to-person contact. We need to get it out of the environment to save lives. T hat means reducing it in cattle. The vaccine will help us get there.
But why should the rancher, feeder or packer bear this expense? Ultimately it will be the purchaser of beef that pays the price. So, Magic Wand, make the government develop and pay for a mandatory vaccination program for beef that will save children’s lives, just like they do for most childhood vaccines available now. The federal government took positive steps to reduce or eliminate Bovine tuberculosis and brucellosis, it should do it for E. coli O157:H7.
It would truly have to be magical, but, when weather permits, washing cattle in the feed lots or on the farms, before loading into trucks and hauling to the holding pens, would effectively reduce the pathogen loads in and around the slaughter facilities.
And the Magic Wand is going to try to find out what truly causes “event days” in beef slaughter facilities so preventive measures can be introduced and implemented by all facilities. And this just might include changes in facility design to reduce pathogens being introduced by measures other than just the cattle.
I think the Magic Wand, if it has any energy left after taking on the payment method for the E. coli vaccination program, will probably do the same thing for Salmonella vaccines in our poultry flocks.
And then the Wand is going to help me convene a high-level conference on antibiotic use in food animals, and the participants will come willing to listen and to learn, and to stop the non-productive claims that are so often repeated. There is a middle ground here that can be reached but, if it is not, Congress will come along and
create problems like it did with catfish inspection.
Speaking of Congress, the Magic Wand will give me the power to immediately rescind the actions of Congress that prohibit FSIS from moving forward with risk-based inspection. This was a budget neutral process that would have increased inspection activities in plants with poor safety records and/or producing high risk products, and would have reduced inspection activities in plants with stellar safety records and plants producing extremely safe products.
The Wand holder feels this will be easier to accomplish now that Congress has mandated in the Food Safety Modernization Act that the FDA use risk as a key element in determining inspection levels and frequency.
While on the subject of high risk products, frozen ground beef patties are a special problem. When cooked in restaurants with validated and documented kill steps, frozen patties are not a problem. But when cooked at tail gate parties, pool parties, camp grounds, etc, we have a problem. I might lend the Magic Wand to someone else and let them decide whether to ban the sale of frozen GB patties at retail, or to require that the meat be irradiated with penetrating beams.
And lastly, while the Wand still has some energy left in it and powers to create change, I am going to try and make that final kill step in all homes and restaurants and institutions a reality. My plan will use the same energy and resources that the government used to educate us all about the switch to cable television and the “dangers” of Y2K to help the American public understand that raw meat and poultry should not be considered sterile.
As a result of this education effort, the majority of the American public will now know how to safely handle raw meats and poultry and, most importantly, how to measure the internal temperature for doneness.
Actually, this should probably have been the first action taken using the power of the Magic Wand. It is by far the most important and will have most immediate effect on the safety of meat and poultry products.© Food Safety News