PITTSBURGH, Pa., Aug. 1, 1995--- U.S. Department of Agriculture proposals to require new food safety procedures in meat and poultry plants are the first step in a long term strategy that will fundamentally transform the Food Safety and Inspection Service and its food safety program, an official said here today.
"Our food safety strategy for the future goes beyond our rule making to implement the HACCP (Hazard Analysis and Critical Control Point) system proposed in February," said Michael R. Taylor, USDA acting under secretary for food safety in remarks prepared for delivery to the International Association of Milk, Food and Environmental Sanitarians.
"To achieve our food safety goal, we must also reinvent the existing FSIS regulations to make them compatible with an entirely new approach to regulation. And we must reinvent FSIS itself--how it defines its regulatory roles, allocates its resources and organizes itself to do its food safety job," Taylor said at the Hilton Hotel and Towers Gateway Center in Pittsburgh.
The FSIS strategy began with rule making proposals in February that would require meat and poultry plants to target and reduce levels of pathogenic organisms in their products. The proposals, which are expected to be finalized and published by the end of the year, also would require all meat and poultry plants to implement the system of process controls called HACCP (Hazard Analysis and Critical Control Point) that would systematically prevent food safety hazards.
Taylor described five key features of the USDA food safety strategy that USDA envisions for the future. He said it will do the following:
Taylor said the FSIS food safety strategy will result in a changed relationship between the regulatory agency and meat and poultry plants as well as reorganization of the agency, which now numbers about 9,500 employees, including an inspection force of about 7,500 full time personnel who work in 6,300 federally inspected plants nationwide.
The USDA food safety official told sanitarians that recent congressional debate on the rule making proposal for meat and poultry inspection focused on how to reform food safety programs, not whether to reform them.
"Everyone agreed on the need for real change to improve food safety, and in particular, meat and poultry inspection," said Taylor, who has served as administrator of the Food Safety and Inspection Service since August 1994 and was named acting under secretary for food safety during last fall's departmental reorganization ordered by Congress.
"A system of preventive controls operated by plant management and overseen by FSIS inspectors will work better to produce safe food, "Taylor said, adding the his agency is currently conducting a "top to bottom" review of its activities in the Washington D.C. headquarters and in five regions throughout the country to ensure that the agency is making the best possible use of its resources.
"Our job is growing, but our resources are not, "Taylor said. "To improve food safety, we simply must make the best use of what we have."
Taylor noted that FSIS is reviewing some 537 pages of meat and poultry regulations and will soon publish a list in the Federal Register of those that need to be amended or repealed to be consistent with the HACCP proposal.
"Any regulations that need to be changed to be consistent with HAACP will be changed before plants will be required to implement HACCP," said Taylor.
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During the last few weeks, public debate in Congress and in the media over regulatory reform has elevated the subject of food safety, including the safety of meat and poultry products, to new levels of public awareness.
Through all of the public debate, there is one thing on which everyone seems to agree--and that is on the need for real change to improve food safety and, in particular, to reform meat and poultry inspection. The debates of recent weeks have focused not on whether to reform our food safety programs but on how to reform them.
One reason for this consensus on the need for change is the simple reality that, despite the past food safety accomplishments to which many in this room have contributed so much, and despite the generally strong food safety record of the American food system as a whole, food borne illness remains an important public health problem in the United States. We have millions of cases of foodborne illness each year and thousands of deaths. Many of these are associated with meat and poultry products, and virtually all are preventable.
A Philosophy of Prevention
This concept of prevention is, I believe the key to understanding the public's reaction to food safety debate, and it is the concept that I believe must organize and drive the efforts of all of us who are engaged professionally in food safety.
People understand that the world is not risk free and that safety--whether it's the safety of airplanes, automobiles, drinking water, or the food supply--is not an absolute. Unfortunately, not everyone understands.
But people do expect that risks that can reasonably be prevented will be prevented. And, when it comes to the safety of food people purchase for their families, they expect that everything that can reasonably by done to ensure its safety has been done.
Ensuring the safety of food is an enormously complex task. Hazards can arise at every stage of the food production process, from the farm to the processing facility, in transportation and storage, in food service establishments and at retail, and by what individual consumers do in their homes. And, at every step along the way, measures can be taken to prevent or minimize hazards.
That is why, in a very real way, everyone is responsible for food safety. And that is why it is wrong to point the finger at any one point in the food safety chain and claim that there is where most of the problem lies.
All of us--in government and all facets of the food industry--should be doing whatever is feasible to minimize and eliminate hazards at every step of the farm-to-table chain. That is how we will deal effectively with the problem of food borne illness in the United States. And that is how we will meet the public's legitimate expectation that those engaged in producing and marketing food to American consumers, and we in government charged with overseeing the safety of the food supply, have done everything it is reasonable possible to do to prevent food safety problems.
The Need for Fundamental Change at FSIS
The Food Safety and Inspection Service (FSIS) bears an important share of the responsibility for preventing food safety problems and reducing foodborne illness. And we have a lot of work to do before we can say that we are fully meeting our responsibility.
FSIS employees are rightfully proud of what they do. Our current system of meat and poultry inspection makes important contributions to the safety and quality of the food supply by enforcing sanitation requirements, excluding diseased animals, inspecting carcasses for visible contamination and defects, and enforcing important food safety standards in processing plants.
But our system is not based sufficiently on the principle of prevention. It is not designed to target and reduce harmful bacteria on raw products. And it does not make the best possible use of the resources the American people have given us to do our food safety job.
To meet our food safety responsibility, we at FSIS must fundamentally transform our program. And I want to tell you today that we have embarked on a process of change that will do just that.
We know that fundamental change does not come easily. But we must ask ourselves whether we are going to enter the next century--and the next millennium--with a new, science-based system of inspection that works effectively to prevent food safety hazards. Or, are we going to stay with a system that does not target the most significant food safety hazards with the most up-to-date preventive measures and that has remained virtually unchanged in its basic approach for decades?
It is clear we must change. And I can assure you that Secretary of Agriculture Dan Glickman and FSIS are committed to a long-term course of very fundamental change.
FSIS Vision of the Future and Strategy for Change
My purpose today is to outline our strategy for change at FSIS and our vision of the future for meat and poultry inspection. Our strategy begins with the rule making initiative we began in February to reduce pathogenic microorganisms and implement HACCP (Hazard Analysis and Critical Control Points) in all meat and poultry plants.
But our strategy goes much further. To make HACCP work and achieve our food safety goal, we must also reinvent the existing FSIS regulations to make them compatible with an entirely new regulatory paradigm. And we must reinvent FSIS itself--how it defines its regulatory role, allocates its resources and organizes itself to do its food safety job. We must also consider legislative change complete the transformation of our program.
Our strategy is intended to change in a fundamental way the relationship between FSIS and the meat and poultry plants we inspect and to create a new system of inspection and oversight that will work better to ensure the safety of meat and poultry products.
We intend to pursue our strategy in close consultation with all of those who have a stake in the success of our program--including producers, processors, food distributors, retailers, the scientific community, consumer organizations, and the public at large.
And we must never lose sight of the fact that the goal of our efforts is safer meat and poultry products.
To achieve this goal, we envision a system that is built on the following core principles:
First, science-based, systematic prevention of food safety hazards must guide the efforts of both government and industry. The current system relies too heavily on FSIS inspectors to detect and correct problems after they have occurred. A system of preventive controls operated by plant management and overseen by FSIS inspectors will work better to produce safer food.
Second, the industry's responsibility for systematically preventing hazards and achieving an acceptable level of food safety performance must be clearly defined, and FSIS must develop objective measures of accountability to verify that meat and poultry plants are meeting their food safety responsibility.
Third, the industry must have the flexibility and the incentive to innovate to improve food safety. Technological innovation in production, slaughter, and processing must be harnessed and applied aggressively if we are to achieve our food safety goals. FSIS must encourage, not stifle, innovation that can improve food safety.
Fourth, we must address the potential hazards that arise throughout the food production and delivery system, including before animals enter FSIS-inspected plants and after meat and poultry products leave those plants. Opportunities exist throughout the system to prevent or minimize hazards and improve food safety.
Finally, the system of government oversight must be structured and operated in a manner that ensures the most efficient and effective use of its resources to improve food safety. FSIS must have the flexibility to target its resources and change the allocation of its resources in a manner that allows it to address significant and emerging food safety problems all along the farm-to-table chain.
Applying these principles, we envision for the future an inspection system that is fundamentally different from the system of today. New detection, process control, and treatment technologies will be in wide use to target, prevent, and reduce contamination with harmful bacteria. FSIS employees will be less involved in daily management of plant activities and more involved in activities to verify that plants are meeting their food safety responsibilities. And FSIS will be transformed from an Agency that focuses virtually all of its resources on visual inspection of products and conditions within meat and poultry plants to one that provides leadership and addresses food safety hazards throughout the chain of production, processing, distribution, and sale.
This is a system that will enhance the contribution every FSIS employee makes to the safety of the food supply. This is a system that will work better for all segments to ensure a safer food supply.
Let me turn now to some of the details of the strategy we are pursuing to transform our program and achieve our vision for the future. Our strategy has three major components.
Proposed Regulations on Pathogen Reduction and HACCP
First, we proposed, in February, regulations that will bring about sweeping changes in our system of meat and poultry inspection--and in what we expect of the meat and poultry plants we regulate. These changes would address the most significant shortcomings in our current system when it comes to preventing hazards and reducing the risk of foodborne illness. We are proposing to directly target harmful bacteria and build the public health principle of prevention into our system by requiring every plant we regulate to adopt HACCP (Hazard Analysis and Critical Control Points). HACCP systems would provide documentation that industry processes are working effectively to prevent hazards and produce safe products. Implementation of HACCP would also clarify that the industry--not government inspectors--have the primary responsibility, and capability, to produce safe meat and poultry products.
Our regulatory proposals would also establish, for the first time, food safety performance standards slaughter plants must meet when it comes to harmful bacteria on raw meat and poultry products, and we propose to require daily microbial testing to verify that the standards are being met. The standards we have proposed do not establish lot release criteria but instead would verify that slaughter processes are being controlled adequately to reduce harmful bacteria in accordance with established targets. With this change, our food safety program would no longer be based solely on organoleptic inspection for raw meat and poultry products but would include microbial testing as a means of ensuring that food safety standards are met for raw products.
By establishing reasonable performance standards plants must achieve, we will be building more objective measures of accountability into the system and we will be providing companies an incentive to innovate, to incorporate process changes and technologies that will improve the safety of their products.
These proposals are not a silver bullet for food safety that will immediately or completely solve all of our food safety problems. But the move to HACCP and performance standards is the critical first step toward the science-based prevention of food safety hazards and the ultimate transformation of our regulatory system.
The HACCP proposal addresses product safety only within the plant environment. But we recognize that ensuring food safety requires taking steps throughout the chain of production, processing, distribution, sale, and handling by food preparers to prevent hazards and reduce the risk of foodborne illness.
That is why the strategy we laid out in February in conjunction with our HACCP proposal includes working with animal producers and others to develop and implement food safety measures that can be taken before animals enter the slaughter facility to reduce the risk of harmful contamination of meat and poultry products. In May, we convened an Animal Production Food Safety Forum at the University of Maryland, which brought together producers, processors, academic and industry scientists, the veterinary medical profession, consumer organizations, and State and Federal government officials for real dialogue on food safety issues and cooperative strategies for addressing them.
To minimize the growth of pathogens once a product leaves the plant, FSIS has also announced its intent to initiate rule making with the Food and Drug Administration (FDA) to establish Federal standards for the safe transportation and storage of foods. there are currently no Federal standards and there is no Federal oversight governing such basic matters as the temperature at which perishable products should be held during transportation to minimize the growth of harmful bacteria. We need to consider such standards and practical approaches to seeing they are met.
And we are working with FDA to ensure food safety at the retail level by encouraging States to adopt and enforce consistent, science-based standards. We know that the primary responsibility for overseeing food safety at the retail level resides properly with state and local governments, and we are elevating our collaboration with those governments and with the FDA on retail food safety.
Because food handlers share the responsibility for food safety, we also will continue our comprehensive education programs to inform the public and those who prepare and serve food to the public on how to properly handle, prepare, and store meat and poultry products to minimize the growth of foodborne pathogens. Safe handling labels, which are now required on all raw meat and poultry products, is one example of an educational strategy USDA has implemented. We also reach the public with food handling information through USDA's Meat and Poultry Hotline and a variety of educational materials.
These proposals and activities along the farm-to-table chain reflect our absolute commitment as an Agency to food safety and consumer protection. Our overriding goal is to prevent foodborne illness. But we cannot achieve our food safety goals unless we change FSIS as well.
Change must occur on two levels. One is regulatory reform. We must ensure that our existing regulations are made compatible with HACCP and our new food safety paradigm. The other is institutional reform. We must fundamentally change FSIS itself. We must change what we do and how we do it to ensure we are making the best use of our resources to improve food safety in our new HACCP-oriented food safety paradigm.
The need to change FSIS takes on even more importance considering current budget realities. Agencies that are not making the best use of their resources in today's budget environment are losing their resources, and maintaining adequate resources is essential to the long-term success and credibility of our food safety program.
Let me address first the regulatory reform element of our food safety strategy and then institutional reform.
Regulatory Reform
Our role on behalf of American consumers, put simply, is to set appropriate standards for food safety and then hold companies accountable for meeting those standards. It is important that companies have the flexibility they need to innovate and efficiently meet their food safety responsibilities and that we focus our efforts on our core standard-setting and accountability functions.
We do not produce food. We cannot make food safe by our efforts alone. And we should not maintain unduly prescriptive "command and control" regulations that obscure or undermine the proper allocation of responsibility between FSIS and the plants we regulate.
We have begun the needed change in our existing requirements by completing a page-by-page review of all FSIS regulations. The results of this review, including the identification of specific regulations we believe need to be amended or repealed to be consistent with HACCP, will soon be published in the Federal Register for public comment. Any regulations that need to be changed to be consistent with HACCP will be changed before plants will be required to implement HACCP.
We will be converting our regulations as much as possible from "command and control" prescriptions to performance standards. We also will be streamlining or eliminating some systems currently required by regulation that result in an inefficient use of public and private resources. We plan to eliminate our prior approval systems for facility blueprints. Processing equipment and most quality control plans. We plan to stop our prior approval of ingredients added to meat and poultry products, which is redundant to FDA's food ingredient safety review. And we will streamline the prior approval system for meat and poultry labels.
Institutional Reform
This regulatory reinvention is essential to our success in improving food safety, but it is not, by itself, sufficient for our success. We must also fundamentally change FSIS itself. As I said, we must change what we do and how we do it to ensure that we are making the best use of our resources to improve food safety in our new HACCP-oriented food safety paradigm. Our job is growing, but our resources are not. We simply must make the best use of what we have to ensure we achieve our goal--a safer food supply.
To help achieve this goal, we are in the midst of a top-to-bottom review of our Agency that is addressing at a very fundamental level how we define our regulatory roles , allocate our resources, and organize ourselves. I hope this review will produce bold options for real change in how we do our job and use our resources.
We know the roles of our inspectors will have to change to implement HACCP and our farm-to-table strategy. We know we need to focus more of our resources on the most significant safety issues and on problems that arise outside of plants. And we know we can streamline our headquarters and field management structures to produce and organization that works both more efficiently and more effectively to improve food safety.
We expect a preliminary report from the top-to-bottom review teams this month. There will be an opportunity for public input on the recommendations. An we intend to make decisions by the end of the year.
We know that the role FSIS plays as an institution is critical to ensuring food safety. That is why reinventing FSIS is an important part of the change needed to improve food safety and an important element of our food safety strategy.
Legislative Mandate
The FSIS food safety strategy I have outlined--encompassing HACCP, reinvention of all existing FSIS regulations and reinvention of FSIS itself--will yield very substantial progress on food safety. It will move the Agency toward a food safety system that meets the public's expectations and satisfies our core principles.
It will be built on science-based prevention of food safety hazards.
It will more clearly define both industry and FSIS responsibilities and enhance accountability.
It will provide the flexibility and incentives industry needs to innovate to improve food safety.
It will address food safety from farm to table.
And it will foster better use of both public and private resources to improve food safety.
Our strategy calls for--and we believe it will achieve--fundamental transformation of FSIS and its program. We also believe that the fundamental transformation we seek could be bolstered by legislative reform.
Many of the food safety and inspection issues we need to address in our farm-to-table food safety strategy are dealt with only generally or not at all in the current meat and poultry inspection statutes. There is an array of other issues that need legislative attention, including the scope of our responsibility for exotic species of food animals, interstate shipment of state-inspected products, and the adequacy of FSIS enforcement authorities in a HACCP environment.
The overall objective of food safety legislative reform should be to make food safer by improving the ability of the Agency to perform its oversight functions and make the best use of its resources. Our legislative authorities, including our statutory mandate for inspection, need to be modernized and strengthened.
USDA wants to work very closely with leaders in Congress, and all interested parties, on legislation that will help achieve our mutual goal of a safer food supply and a system of regulatory oversight that is more effective and more efficient--a system that is better able to meet public expectations and retain public confidence.
Conclusion
This is a time of enormous opportunity for progress on food safety. There is much common ground on the need for change and the necessary direction of change. We will achieve our common goal of a safer food supply by recognizing that all of us are responsible for food safety and by all of us taking responsibility--in our government offices, in our businesses, and in our daily lives-for doing what we can to improve food safety.
There is so much to be gained by working hard--and working together--to change our food safety system and achieve our goal of a safer food supply.
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