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Should the Microbiological Data Program Be Saved?

Maybe ... Maybe not...

Opinion

After nearly being chopped from existence, the USDA’s Microbiological Data Program (MDP) has been saved for the remainder of 2012. However its future existence is questionable.

MDP is a national foodborne pathogen monitoring program implemented in 2001. Through cooperation with State agriculture departments and other federal agencies, MDP manages the collection, analysis, data entry and reporting of foodborne pathogens on selected agricultural commodities at the retail level.

At issue for MDP are its operation and funding. That is, although it is housed by the USDA, many, including USDA Secretary Tom Vilsack and the United Fresh Produce Association (UFPA), are publicly stating that it should be operated by the FDA. However, just as USDA does not have the $4 million funding for the program, neither does FDA–nor has FDA requested responsibility for it or have the resources to take on its operation, particularly as the Agency continues to work to roll out FSMA (if OMB would ever move the provisions off its desk).

As explained in an article in The Produce News last week, “The Obama administration did not request funding for MDP…. Neither the House nor the Senate bills include funding, but the measures have yet to gain final approval.”

MDP was designed to provide monitoring data on pathogenic E. coli (STEC), E. coli 0157:H7, Listeria monocytogenes, and Salmonella spp in selected fruits and vegetables at retail. It collects samples from 11 participating states, representing about 50 percent of the nation’s population and all regions of the country. Collaborating with CDC, MDP communicates immediately any pathogens isolated from MDP samples.

The MDP program is one of those federal programs that has a tendency to polarize opinions. In short, the industry hates it and consumer organizations love it. So why the polarity and what is a reasonable middle ground?

The first problem with the program is that oftentimes by the time a positive is found, the product is not only in the market place but likely consumed or close to its expiration date – so there is little to no direct public health protection following detection of a positive sample.  Second, the tracking/supplier data around that produce is often not robust, so it can be a major challenge to determine which lot numbers to recall or which farms/processors are implicated. Thus recalls get broad and FDA has little data to go on to explore the original source of the problem.

So is there a good side to this program? It is currently the only program that provides a glimpse of the prevalence of key microbial agents in high-risk fresh produce, so from that perspective, it provides good information. If the sampling were done at the correct place in the supply chain with the correct data by the correct Agency with appropriate funding, it could be both a public health win and tolerable for the produce industry.

So what does this Utopian MDP program look like that will allow it to continue to provide useful information? How about something like the following:

- Hold product while MDP conducts tests to eliminate consumer exposure to any positive samples.

- Ensure that when a sample is taken, the product tracking information is complete to allow FDA to narrow down the source quickly.

- Put the program under the Agency that has responsibility for produce – FDA.

- Fund the program so that it can operate quickly and efficiently.

While FDA is not eager to take on the program, it has acknowledged its value to the Reportable Food Registry (RFR).  The FDA released its second annual report on the RFR in April (covering the September 2010-September 2011 reporting period). As reported in an April 23 article in The Packer, the FDA said part of the reason that there was an increase in produce primary reports was because of alerts from the MDP. According to the FDA report, “While this information is intended to determine the effectiveness of procedures to reduce or eliminate harmful microorganisms, the results of MDP tests are shared with RFR responsible parties who may be required to submit the information to the (registry).”

While supporting a testing program by FDA that is “scientifically accurate and effective in monitoring and protecting public health,” UFPA has, however, also urged the elimination of the MDP. According to an AP report, it wants the private sector to do more of its own testing, saying that MDP has cost growers millions in produce recalls and unfairly targeted farmers who aren’t responsible for contaminating the food, since testing at the retail level means that contamination could have occurred at any prior point in distribution.

Like many federal programs, if the MDP program was redesigned with input from the food industry, in this case the produce sector, it could be a lot more effective, less costly to the industry and provide better data.  But maybe I am being too logical!

—–

Note: This has article has been corrected. The article originally stated that MDP samples at the retail level when in fact the program pulls samples at produce distribution centers.There are a few exceptions: MDP allows states to collect at retail level when the product is not available at the distribution level and it is bagged or in a sealed container. 

David Acheson, former Assistant Commissioner for Food Protection in the FDA, is a partner at Leavitt Partners. This commentary was originally posted July 26, 2012 on the Leavitt Partners Food Safety blog.

© Food Safety News
  • Jennifer Watson

    Mr. Acheson is a little blurry on his facts. He states that MDP should collect its samples at distribution centers before the produce enters the retail market. All the news articles and the MDP website http://www.ams.usda.gov/mdp make it clear that this is where samples are taken, not at retail.

  • MicroNerd

    I think you make some very valid points, however I do not believe the solution would be for the private sector to do their own testing. I’m not allowed to grade my own tests, am I? And with big produce companies often putting profit margins before human health, I can’t see that as objective.

  • Dr. Lisa McGreggor

    Dr Acheson, I have met several of the MDP scientist at meeting and am familiar with this program. You changed a statement in your article which Ms Watson (above addressed) and replaced with the comment that the lots of food sampled by MDP should be held until testing is complete. You further state that this would be more palatable to industry???? This notion is absurb. Testing is very rapid today and if clean, test can confirm this within 48 hrs using current MDP procedures. The problem is that MDP test uses PCR which can detect very low levels of pathogens. It also will detect DNA whether from dead cells or alive. Further more, there can be rare cross reactivity for the target DNA with DNA from similar bacterium. When this happens, MDP scientist are very careful and do not report positives until they obtain an actual isolate. This takes time (a week, sometimes more) using selective media’s to get the pathogen out of the all the background microfloa.
    If industry is upset at the few positives that MDP finds, what will they say about holding additional lots until they can confirm the pathogen is or is not there given a PCR positive? I can see lawsuite by industry against the program given the short shelf life of produce holding up lots for sale to wait for testing.
    MDP sample collectors gather as much information as they can off the containers, much of it is unavaliable-this is an industry issue. United Fresh and PMA need to get thier constituency on board and come up with uniform labeling and tracking methods.
    While you were commissioner of FDA, what efforts did you make to move MDP to FDA? It nerves me that you make these statements and did nothing while you had the position and opportunity to have made this happen. Have you gone to the current commission of FDA to suggest this?
    Yes, there are things MDP could improve on and do better. Some of your suggestions are perposterous!
    Dr. Lisa McGreggor