By Robert E. Brackett
The American Frozen Food Institute (AFFI), together with the International Dairy Foods Association (IDFA); FMI – The Food Industry Association (FMI); Produce Marketing Association (PMA); and National Fisheries Institute (NFI) recently hosted a Food Safety Forum aimed at critically looking at the current regulatory policies for Listeria monocytogenes (Lm) and exploring new ways of addressing the Lm issue that would result in reductions in cases and outbreaks of listeriosis. If you missed the forum, you missed a great discussion. For those of you who were not able to join us, I thought I would share some observations and thoughts.
The forum was prompted by the increased number of recalls of ready-to-eat (RTE) foods due to the presence of Lm, owing to the current “zero tolerance” policy by the U.S. Food and Drug Administration (FDA) and U.S. Department of Agriculture’s Food Safety Inspection Service. AFFI, IDFA, FMI, PMA and NFI definitely accomplished their goal of providing an in-depth discussion of the existing science surrounding Lm, as well as implications for regulatory policy. This program attracted over 700 registrants from multiple countries, some of which currently have regulatory limits on Lm in place.
Overall, the program was well thought out and covered most of the pertinent issues surrounding both the current policy as well as new ideas on ways to deal with Lm. After a brief welcome and introduction by AFFI President and CEO Alison Bodor, FDA Deputy Commissioner for Food Policy and Response, Frank Yiannas, and USDA Deputy Undersecretary for Food Safety, Sandra Eskin, provided their perspectives on Lm and set a positive tone for the presentations and roundtables that followed.
In addition to the two keynote presentations mentioned above, the organizers broke the forum into three broad areas of discussion:
- The scientific foundation of why Lm is such a challenging public health issue
- Discussions from industry and academic experts on how we can translate the science into actionable practice
- Observations from industry representatives on how the current policy is impacting their business and how a risk-based system could work with their products
Each of the well-known Listeria experts presenting in the first discussion addressed different aspects of Lm in the food supply. Dr. Martin Wiedmann focused his presentation on the important distinction between hazard-based vs. a risk-based approach to public health policy. The practical implications of these two philosophies are represented by a “zero tolerance” to the presence of any viable Lm in the first case, as opposed to an acceptable regulatory limit in the case of risk-based approach. Dr. Wiedmann convincingly argued that risk-based strategies to control foodborne illness are more likely to lead to positive public health outcomes. In one case, he was able to show that implementation of a performance standard could result in half the risk provided by the current FDA regulatory policy of zero viable Lm in 25 grams of food. Based on questions from attendees, this caught peoples’ attention.
Well-known food microbiologist, Dr. Jeff Farber spoke next on the science panel. Dr. Farber gave a very comprehensive discussion on Listeria biology, infectivity, and profiles of some listeriosis outbreaks associated with what most people would consider low risk foods, such as ice cream and frozen vegetables. Dr. Farber made the point that if we are to make progress in reducing cases and outbreaks of listeriosis, we must be more aggressive at seeking out Lm and its harborages. To that end, Dr. Farber introduced a novel three-class sampling scheme that, together with a regulatory limit of 100 cfu/g, would better catch both frequent low level contamination events as well as occasional high-level contamination, thereby reducing risk to consumers. Moreover, implementing such novel sampling schemes would also reduce the need for recalls of low-risk foods.
Noted epidemiologist Dr. Craig Hedberg provided modeling data to also support the notion that a risk-based system encourages more aggressively looking for Lm in the food production area and would lead to fewer cases of listeriosis.
The second panel was comprised of noted academic and industry food safety leaders who discussed how the science presented in the first panel could be put into practice. Each gave examples from their own experience on the limitations of the existing policies and contrasted how Listeria management in the U.S. differed from that of the international community, specifically the European Union and Canada, and how Listeria policy could be harmonized such that it did not adversely impact trade and public health. Dr. Sanjay Gummalla also summarized the effort put forth by AFFI to organize AFFI’s Lm Expert Panel, and how this group was used to initiate science-based discussions with regulators.
The final panel discussed how the Listeria issue is being addressed in different sectors of the food industry and how a move toward a risk-based policy could or would change their efforts. Panel members represented the dairy, seafood, fresh produce, frozen, and the retail sector. This panel enjoyed a robust discussion on how moving to a risk-based policy would strengthen their Listeria control efforts, particularly when they could track down Lm without fear of regulatory action against them. One particularly bold audience member asked the group if they would be willing to participate in a pilot program hosted by AFFI. All agreed that it was worth the effort if it could move Listeria control forward and reduce listeriosis cases.
As I mentioned in my introduction, if you missed the forum, you missed a lot. The discussions that resulted from this program were among the most candid and compelling than I have seen in years. However, you have the opportunity to see the Forum for yourself. You can watch the four session recordings from AFFI’s Food Safety Forum by clicking here. Regardless of which side of the “zero tolerance” issue you are on, it is clear that what we have been doing is not leading to a reduction in listeriosis cases. Perhaps it’s time for the food industry and regulators to be bold and try something new. Hopefully, this forum will be viewed by regulators and the food industry as a start, rather than a conclusion.
About the author: Robert E. Brackett, PhD, is a former FDA Director of Center for Food Safety and Applied Nutrition. He has over 35 years of experience in food safety research, training, and policy. Brackett worked in academia, government, and industry including Illinois Institute of Technology’s Institute for Food Safety and Health, the Washington D.C. based Grocery Manufacturers Association, the U.S. Food and Drug Administration’s Center for Food Safety and Applied Nutrition (FDA CFSAN), and several other positions. Brackett is a member and Fellow in the International Association for Food Protection, the Institute of Food Technologists, and the American Academy of Microbiology. He is also a member of the American Society for Microbiology, Association of Food and Drug Officials, AOAC, and the Food and Drug Law Institute. He has been honored with the FDA Award of Merit, the FDA Distinguished Alumni Award, the Department of Health and Human Services Secretary’s Award for Distinguished Service, the International Association for Food Protection’s President’s Appreciation Award, and, the William C. Frazier Food Microbiology Award. Brackett received his doctorate in food microbiology from the University of Wisconsin-Madison.