Caroline Smith DeWaal Food Safety Director, CSPI Feb. 16, 2012 Tampa, Florida NATIONAL TURKEY FEDERATION ANNUAL CONVENTION.

Caroline Smith DeWaalFood Safety Director, CSPIFeb. 16, 2012Tampa, Florida

NATIONAL TURKEY FEDERATION

ANNUAL CONVENTION

Bi-national consumer advocacy organization founded in 1971 by Michael Jacobson, Ph.D.

Focuses on nutrition, health, and food safety

Publishes award-winning Nutrition Action Healthletter

Represents over 900,000 subscriber/ members in the U.S. and Canada

CSPI: FOUR DECADES OF CONSUMER ADVOCACY

New Poultry Inspection System (P.I.S.)Emerging PathogensPerformance Standards

FSMASafe Meat and Poultry Act

Outbreak Alert!: Results from 1999-2008 for the turkey industry

CHARTING OUR COURSE

3

Major overhaul of poultry inspection announced last month

Agency stresses that this is not HIMP… Data on HIMP is less than definitive:

No thorough independent review since 2001 Testing data show some plants exceed the performance

standards; others do notClear that the poultry inspection system needs

updating: Goals of new P.I.S:

Decrease risk of foodborne illness Decrease expenses for government and industry Focus FSIS inspectors on aspects most related to food

safety

Worthy goals, but are these steps the right ones?

NEW POULTRY INSPECTION SYSTEM

Establishment must document plans to prevent: Carcass contamination by enteric pathogens and fecal

material, and to enforce zero tolerance for fecal contamination entering the chill tank.

Establishments must test to validate the eff ectiveness of those plans.

Establishments must maintain enhanced recordkeeping requirements to document that products meet the definition of ready-to-cook (RTC) poultry.

Devil is in the details– some proposed ‘improvements’ need fleshing out before we will know how eff ective they’ll be.

THE NEW P.I.S. IMPROVEMENTS

Mandatory elements (aff ecting all 289 poultry, non-ratite establishments):New testing conducted by each facility but the

adequacy of testing regime is unclear: no required frequency or target organisms Removal of previous testing requirements for generic

E. coli

Replacement of prescriptive time/temperature chilling with requirement for establishment-developed procedures Aligned with HACCP, but Agency must review SIP

waivers to determine effectiveness of alternative methods

THE NEW P.I.S.WAIT-AND-SEE

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Voluntary elements (aff ecting those establishments operating under the new P.I.S.):Reassignment of carcass sorting activities from FSIS -

inspector to the establishment Who sets the standards for sorting? How much

discretion do they have? Is there adequate training for sorters?

Line speed changes Is “stopping the line” a real enforcement tool for

inspectors? How frequently do they use it, and do they feel pressured to avoid doing so?

What is the line speed for the company sorter?

THE NEW P.I.S.WAIT-AND-SEE

RECOGNIZING EMERGING PATHOGENS AND NEW VEHICLES

E. coli O104:H4 sprout outbreak in Europe, summer 2011 Over 4300 ill, 900+ HUS cases, approx. 50 deaths

S. Heidelberg outbreak in ground turkey in 2011 26 states, 136 ill, 37 hospitalizations, 1 death

Listeria monocytogenes cantaloupe outbreak in Colorado, fall 2011 At least 30 deaths

Ubiquitous, grows at refrigeration temperatures

ANTIMICROBIAL RESISTANT OUTBREAKS

Mostly Salmonella Ground beef and unpasteurized dairy products most common sources

Ground turkey – 2 outbreaks in 2011, S. Hadar and S. Heidelberg

Ground beef – 7 outbreaks since 2002, S. Newport and S. Typhimurium

The Food Safety Modernization Act passed Congress and was signed into law on January 4, 2011.

It is the beginning of a longer term eff ort to modernize the national food safety system.

The legislation has no specific impact on the meat and poultry industries, but there are elements to consider.

The provision on Performance Standards requires consultation with the Secretary of Agriculture to determine the most significant contaminants.

MODERNIZING FOOD LAW IN THE UNITED

STATES: PERFORMANCE STANDARDS

FSMA REQUIREMENTS FOR DEVELOPING PERFORMANCE

STANDARDS

New law requires FDA to take a number of steps in setting performance standards:Determine the most significant foodborne contaminants

Emphasis on contaminants with robust public health data

Pathogen–food category pairing demonstrates the need for good attribution data

Set guidelines or regulations requiring industry controls by product or product classesRe-evaluate list of significant contaminants every two years; periodically review guidance or regulations

If enacted, SMPA would:

Update food safety laws governing the meat and poultry industry to better protect public health through a more integrated food safety system.

Provide the Food Safety and Inspection Service at USDA with statutory direction on managing new and emerging pathogens.

Require FSIS to conduct a public health assessment to improve understanding of the risks associated with meat, poultry and egg products to inform public education and research efforts.

SAFE MEAT & POULTRY ACT, S. 1529

Under this provision, FSIS will have a clearly defined program for determining which pathogens pose the greatest risk to public health and establishing standards that reduce that risk.

A performance standard establishes the degree to which “a step or combination of steps in the production, processing, distribution, or preparation of a food must operate to achieve the required level of control over microbiological contamination.”

A statutory mandate would provide the industry with greater certainty regarding its responsibilities.

PERFORMANCE STANDARDS UNDER SMPA

FSIS is required to:Conduct a survey to determine current levels

of food contamination. Establish public health goals and objectives. Define pathogen reduction performance

standards that are suffi cient to reduce pathogens in food and achieve public health goals and objectives.

 To assure the effectiveness of the standards –

they are reviewed every three years against the goals and availability of improved controls.

PERFORMANCE STANDARDS

The bill complements the recently passed FDA Food Safety Modernization Act; it would establish better targets for pathogen control, stronger surveillance for foodborne diseases, and new traceability and recall authority.

These steps will help reduce the risk of foodborne disease outbreaks, or provide faster detection and response if an outbreak occurs.

HOW SMPA FITS WITH FSMA

CSPI’s database uses outbreak information primarily from the CDC – only analyzing foodborne outbreaks with identified food sources and etiologies.

Between 1999 and 2008, CSPI analyzed 4,742 outbreaks, which caused 120,570 illnesses in the U.S.

The database is updated and reports are published regularly.

OUTBREAK ALERT!

TURKEY OUTBREAK TRENDS ILLNESSES

TURKEY OUTBREAK TRENDSPATHOGENS

RELATIVE RATES OF ILLNESS

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Dairy

Fruits

Vegetables

Eggs

Pork

Beef

Chicken

Turkey

Seafood

0 5 10 15 20

1.00230054536059

1

2

5

6

8

8

18

18

Relative Rates of Illnesses by Food Category Adjusted for Consumption, 1999-2008

N=88,433 Illnesses 2,682 Outbreaks

Number of Illnesses relative to those caused by Dairy Products

Illnesses per Billion Pounds Consumption 1999-2008

Yearly Average Illness Data from Outbreak Alert!

Yearly Average Consumption (Billion lbs.) USDA ERS Data

Illnesses/Billion lbs. Relativ

e Rate:

Beef 1035 11.95 87 8Dairy 622 55.33 11 1Eggs 333 6.35 52 5Pork 491 8.07 61 6Produce 2785 91.54 30 3Fruits 462 38.86 12 1Vegetables 1195 51.79 23 2Seafood 634 3.12 203 18Poultry 1287 12.28 105 10

Turkey 512 2.61 196 18Chicken 834 9.67 86 8

CONSUMPTION AND ILLNESSES TURKEY VS. CHICKEN

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Most commonly identified foods in CDC’s line-listing:Turkey – 21Roasted turkey – 21Smoked turkey – 11Baked turkey – 8Deli meat, sliced turkey – 10Sandwich, turkey – 25Turkey, gravy – 8Turkey, stuffi ng – 8

TURKEY PRODUCTS IMPLICATED

THANK YOU!

Caroline Smith DeWaalFood Safety Director

Center for Science in the Public Interest1220 L St., NW Suite 300

Washington, DC 20005

Phone: (202) 777-8364 Fax: (202) 265-4954E-mail: [email protected]

On the internet: www.cspinet.org and www.safefoodinternational.org