The U.S. Department of Agriculture’s announcement Tuesday that it is moving toward mandating a test-and-hold policy for the meat and poultry industry drew some praise, but the overall consensus seems to be that while the change is a positive step — USDA says it would have prevented 44 Class 1 recalls in the last three years alone — a mandatory policy is likely not all that significant.

As Food Safety News reported yesterday, the practice of waiting for microbiological or residue test results before shipping product into commerce has already been widely adopted in the industry. The American Meat Institute enthusiastically supports the change, though USDA officials have not indicated what percentage of processors are not practicing test-and-hold.

“[The new policy] is not earth-shattering,” says Sarah Klein, a food safety attorney at the Center for Science in the Public Interest. “Close to 100 percent of the large establishments, and probably 80 percent of smaller processors, are already doing this.”

Nonetheless, Klein says CSPI is pleased with the agency’s decision to use its regulatory power so processors have to “earn” the USDA mark of inspection.

“We’re not interested in a gotcha system,” she added. “We’re not interested in having more recalls. So to the extent that this prevents recalls, that is in the public’s interest.”

Former Under Secretary for Food Safety, Dr. Richard Raymond, said his team looked at making test-and-hold mandatory under the Bush administration, but ultimately decided not to pursue the policy for two reasons: most processors are already holding product and the public health benefit is not clear.

“This is an extremely small percentage we are talking about here,” said Raymond. “It is an onerous issue for these very small plants,” he added, explaining that smaller grinders, for example, might not have the fridge capacity to hold product for a couple days until FSIS gets back to them on their tests, and their local customers might rely on them for short-notice orders. Raymond called the policy proposal a “political play” to reduce the number of embarrassing recalls, which ultimately remind consumers that meat can make you sick.

John Munsell, a former meatpacker based in Montana (see a profile on Munsell here), reiterated that the proposed change is aimed at recalls. Munsell called on the agency to go beyond test and hold to a more progressive system where contamination is traced back to its original source.

“The agency’s primary motive here is to reduce the number of recalls. Period,” he wrote in an email to Food Safety News. “Why? Because recalls are an embarrassment to the agency, as well as to the industry.  If these 44 recalls had not occurred, the agency would be empowered to state that their proactive meat inspection system has successfully resulted in a dramatic reduction in the amount of contaminated meat produced.”
Munsell, a fierce critic of FSIS testing policies since his infamous 2002 run in with E. coli (which was ultimately linked to a 19.1 million pound ConAgra recall), said he believes the primary reason for the policy shift is “for PR image purposes.”

“Mandatory [test and hold] hold does reduce the number of embarrassing recalls, but with the agency’s historical unwillingness to trace back to the [source], and force the source to clean up its act, we are virtually guaranteed ongoing outbreaks,” he added. FSIS is not required to look upstream in the supply chain to see where contaminated meat might have originated, a practice that could lead to widened recalls.

Munsell also pointed out that many of the large-scale meatpackers have their own in-house labs, which allows quick turnaround time for test results. “Small plants must FedEx the meat to outside labs, and it took us 2 days’ minimum to obtain a confirmed negative, or 3 days for a confirmed positive. The USDA positives on samples from my plant all required four days.”

Carol Tucker-Foreman, a distinguished fellow in food policy at Consumer Federation of America, called USDA’s decision a “useful step” but echoed Munsell’s call for improving traceback. 

“[I]t would be much more meaningful if this step were accompanied by an FSIS/USDA commitment to track all STEC positives back to the slaughterhouse, not just those that resulted in illnesses and recalls,” she said in an email. “Tracing the contaminated product back to its source — whenever a positive is found – -would improve accountability at the slaughterhouse and the farm.”

Klein also pointed out that the new test-and-hold policy will only be as strong as the validity of the testing method.

“The separate question then becomes, is their testing system sufficient for catching contamination?” Klein added that discussions and improved data collection are necessary to move USDA’s testing protocols forward.

USDA Inspector General Phyllis Fong last month questioned the validity of FSIS’ current E. coli O157:H7 sampling program, recommending that the agency place its testing process on “sounder statistical ground” by redesigning its sampling methodology to account for different levels of contamination.