An Evaluation of the USDA’s Policy to Reduce Listeria Illnesses in Ready-to-Eat Meat and Poultry Products Travis Minor a , Matt Parrett b, * a United States Department of Agriculture, Economic Research Service, 1400 Independence Avenue SW, Washington, DC 20250, United States b Food and Drug Administration, 5001 Campus Drive, College Park, MD 20740, United States Abstract Using 1998-2008 data collected by the Centers for Disease Control and Prevention on foodborne illnesses and outbreaks, we examine the economic impact of the United States Department of Agriculture’s proposed and final rules to reduce the incidence of Listeria monocytogenes (Lm) in ready-to-eat meat and poultry products. Using a difference-in-differences approach, we find that these rules together reduced meat-related Lm illnesses by about 60 per year. We attribute this decline to reductions in both the number and average size of meat-related Lm outbreaks. Finally, our reevaluated estimate of the rules’ benefits compares favorably to their estimated cost. Keywords: Listeria monocytogenes, ready-to-eat, meat, poultry, regulation JEL Classification Codes: I18, Q18 __________ The views expressed here are those of the authors and may not be attributed to the Economic Research Service, the United States Department of Agriculture, or the Food and Drug Administration. *Corresponding author. E-mail addresses: [email protected] (T. Minor), [email protected] (M. Parrett)
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An Evaluation of the USDA’s Policy to Reduce Listeria Illnesses in Ready-to-Eat Meat and
Poultry Products
Travis Minora, Matt Parrett
b, *
aUnited States Department of Agriculture, Economic Research Service, 1400 Independence
Avenue SW, Washington, DC 20250, United States bFood and Drug Administration, 5001 Campus Drive, College Park, MD 20740, United States
Abstract Using 1998-2008 data collected by the Centers for Disease Control and Prevention on foodborne illnesses
and outbreaks, we examine the economic impact of the United States Department of Agriculture’s
proposed and final rules to reduce the incidence of Listeria monocytogenes (Lm) in ready-to-eat meat and
poultry products. Using a difference-in-differences approach, we find that these rules together reduced
meat-related Lm illnesses by about 60 per year. We attribute this decline to reductions in both the number
and average size of meat-related Lm outbreaks. Finally, our reevaluated estimate of the rules’ benefits
In the wake of a 1998 outbreak of Listeria monocytogenes (Lm)1 involving hot dogs and
deli meats and causing 101 illnesses, 15 adult deaths, and 6 stillbirths or miscarriages, the United
States Department of Agriculture (USDA) published a proposed rule in February 2001 titled
“Performance Standards for the Production of Processed Meat and Poultry Products” (United
States Department of Agriculture, 2001). The rule, hereafter referred to in its entirety as the
Proposed Standards and Lm Rule, proposed that all ready-to-eat meat and poultry products, as
well as all partially heat-treated meat and poultry products, meet various food safety standards.
The lethality and stabilization standards, respectively, established levels of pathogen reduction
and limits on pathogen growth that establishments covered by this rule would need to achieve.
The handling standard would require that covered establishments maintain these levels of
pathogen reduction and growth in their products under normal handling conditions and until their
products reach the consumer. This rule also proposed to eliminate regulations mandating that
ready-to-eat and not-ready-to-eat pork and products containing pork be treated to destroy
Trichinella spiralis. Lastly, this rule proposed testing requirements aimed at reducing the
occurrence of Lm in ready-to-eat meat and poultry products. More specifically, this piece of the
proposed rule, hereafter referred to as the Proposed Lm Rule, would require that establishments
that produce ready-to-eat meat and poultry products test food contact surfaces for Lm following
lethality treatment but before final product packaging to verify that their Sanitation Standard
1 The infection caused by eating food contaminated with the pathogen Lm is known as listeriosis (Centers for
Disease Control and Prevention, 2016). The symptoms of listeriosis are fever and diarrhea (Centers for Disease
Control and Prevention, 2017). Invasive listeriosis, a much more severe form of listeriosis in which the pathogen
Lm has spread beyond the gut, causes, in pregnant women, fever, fatigue, and muscle aches and can lead to
miscarriage, stillbirth, premature delivery, or life-threatening infection of the newborn (Centers for Disease Control
and Prevention, 2017). In people other than pregnant women, symptoms of invasive listeriosis can, in addition to
fever and muscle aches, include headache, stiff neck, confusion, loss of balance, and convulsions (Centers for
Disease Control and Prevention, 2017). Listeriosis is most likely to sicken pregnant women and their newborns,
older adults, and individuals with weakened immune systems (Centers for Disease Control and Prevention, 2016).
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Operating Procedures (Sanitation SOPs) are preventing direct product contamination by Lm after
the lethality treatment. If a food contact surface is found to test positive for Lm, then the
establishment would be required to take corrective actions.2
In June 2003, in the wake of a 2002 outbreak of Lm involving turkey deli meat and
causing 29 illnesses, 4 deaths, and 3 miscarriages or stillbirths, combined with recent recalls of
meat and poultry products adulterated by Lm, the USDA issued an interim final rule3 (United
States Department of Agriculture, 2003). This rule, which became effective in October 2003 and
is referred to hereafter as the Final Lm Rule, requires that establishments that produce ready-to-
eat meat and poultry products that are exposed to the environment following lethality treatment
and that support the growth of Lm have in their HACCP plans or in their Sanitation SOPs or
other programs controls that prevent product adulteration by Lm.
In this paper, we test using a difference-in-differences approach whether the Proposed
and Final Lm Rules described above decreased the number of meat-related Lm illnesses. To do
this, we use novel 1998-2008 data on foodborne illnesses and outbreaks by commodity and
pathogen collected by the Centers for Disease Control and Prevention (CDC) and compiled by
Painter et al. (2013). For purposes of this analysis, and consistent with the coverage of the
Proposed and Final Lm Rules, meat comprises beef, pork, and poultry.
2 Establishments who in their Hazard Analysis and Critical Control Point (HACCP) plan have identified Lm as a
hazard reasonably likely to occur, and have established critical control points (CCPs) validated to eliminate Lm from
their products, would be exempt from this testing requirement. HACCP is a preventive system of hazard control. 3 The typical first stage of the rulemaking process is the Advanced Notice of Proposed Rulemaking (ANPRM). An
ANPRM is essentially an announcement to the public that the agency authoring the ANPRM is interested in making
a rule. There is usually a comment period associated with an ANPRM, whereby the public is given the opportunity
to send comments to the agency authoring the ANPRM about the rule in question. The typical second stage of the
rulemaking process is the Proposed Rule. A Proposed Rule clearly defines and makes a case for the rule in question.
Like with an ANPRM, there is usually a comment period associated with a Proposed Rule. The typical third stage
of the rulemaking process is the Final Rule. An agency might instead issue an Interim Final Rule. Final Rules and
Interim Final Rules carry legal authority. In contrast, the public is not legally compelled to adhere to anything
promulgated in either an ANPRM or a Proposed Rule. The difference between an Interim Final Rule and a Final
Rule is that there is usually a comment period associated with an Interim Final Rule, after which the Interim Final
Rule is normally finalized and becomes a Final Rule.
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This paper ties most closely to the literature on food safety standards. A number of
studies in this literature look at the effect of food safety standards, most notably HACCP, on the
microbiological quality of foods, finding that they are effective in improving the microbiological
quality of the food or foods studied (e.g., Soriano et al., 2002; Cenci-Goga et al., 2005; Amoa-
Awua et al., 2007; Hong et al., 2008; Wang et al., 2010; Nada et al., 2012). A smaller number of
studies centers on health effects. We know of just two studies, Asfaw et al. (2010) and Okello
and Swinton (2010), which examine the effect of food safety standards on the health of the
producer and two studies, Vojdani et al. (2008) and Minor and Parrett (2017), which look at the
effect of food safety standards on the health of the consumer. The focus of Vojdani et al. (2008)
and Minor and Parrett (2017) is on the effect of a Food and Drug Administration (FDA) final
rule published in January 2001 aimed at reducing the number of foodborne illnesses associated
with juice products. These studies, respectively, find that the January 2001 rule reduced juice-
related outbreaks and illnesses. Our paper fits closest to this latter, consumer health strand of the
food safety standards literature and, to the best of our knowledge, is the first to examine the
impact of the Proposed and Final Lm Rules on the number of meat-related Lm illnesses.
Our work is important from a policy standpoint because it informs the economic impact
analysis of the Final Lm Rule, referred to as the Final Regulatory Impact Analysis (FRIA). Such
an analysis consists of estimates of a rule’s costs and benefits and by Presidential Executive
Order is a required part of the regulation promulgation process. Using our estimates of the
combined effect of the Proposed and Final Lm Rules on the number of meat-related Lm illnesses,
we reevaluate the benefits of the Final Lm Rule that were estimated by the USDA in the Final Lm
Rule FRIA. We consider the combined impact of the Proposed and Final Lm Rules in our
reevaluation because existing evidence suggests that the public responds to proposed rules
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(Strom, 2012; Thrasher, 2013; Minor and Parrett, 2016), presumably in anticipation that such
rules will eventually be finalized.
The layout of this paper is as follows. Section 2 provides a description of the data used in