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United States Department of Agriculture Food Safety and Inspection Service The FSIS Role in Food Safety Who’s Minding the Store? The Current State of Food Safety and How It Can Be Improved David Goldman, MD, MPH Assistant Administrator Office of Public Health Science Food Safety and Inspection Service April 11, 2008 United States Department of Agriculture Food Safety and Inspection Service FSIS Mission •Protect consumers by ensuring that meat, poultry, and egg products are safe, wholesome, and accurately labeled. •With FDA, responsible for ensuring the Healthy People 2010 food safety goals •Incorporate food safety objectives into agency strategic plan and OMB reporting United States Department of Agriculture Food Safety and Inspection Service FSIS Workforce • 10,000 total personnel—of that number 7,500 are inspection and veterinary personnel • 6,300 plants have FSIS inspectors present in them every day, as required by our acts • 100 billion pounds of meat, poultry and liquid egg products are verified safe by FSIS each yr • Inspects product that represents more than one-third of all consumer spending on food in the U.S. and about 40% of all domestic food production United States Department of Agriculture Food Safety and Inspection Service FSIS Profile • Forerunner organization established in 1906 with passage of the Federal Meat Inspection Act • Agency has historically been focused on inspection activities • Public health mission has evolved more recently United States Department of Agriculture Food Safety and Inspection Service FSIS Profile • HACCP Rule passed in 1996 • Focus on verification of establishment pathogen control – Increased product testing – Collaboration with PH partners in foodborne illness investigations • Founding partner of FoodNet in 1996 • Member of PulseNet United States Department of Agriculture Food Safety and Inspection Service FSIS Application of Public Health Model Assessment (Reassessment) Assurance Quantitative risk assessments Other scientific assessments Evaluation • Food data • Human data • Animal data • Environmental data Policy Development United States Department of Agriculture Food Safety and Inspection Service HP2010 Food Safety Goals • Reduce infections caused by key foodborne pathogens; targets were set at 50% of the illness rate in 1997 United States Department of Agriculture Food Safety and Inspection Service FSIS Initiatives for E. coli O157:H7 • FSIS target = 0.2% prevalence in ground beef (20042006 rates each 0.17%; preliminary 2007 rate=0.24%) • Recent baseline in beef trim (major component of GB) • Routine trim testing • More aggressive follow-up testing of positive tests • Risk-based sampling based on testing history and volume • New micro testing methodology • Update to E. coli O157 risk assessment: – model both the contribution of all ground beef components; and, – effect of industry interventions • Consideration of primal cuts and non-O157 STEC United States Department of Agriculture Food Safety and Inspection Service FSIS Initiatives for Salmonella • February 2006 announced new sampling/testing strategy • Focus initially on broilers, having increasing contamination rates and known vehicle for human illness • More agency testing would be done in plants with higher rates of contamination or harboring serotypes of human health concern • Agency goal: move plants to lower contamination rates • This new approach resulted in a change in our performance measure as reported to OMB – From: overall percent of samples positive for Salmonella – To: percent of plants performing at desired level United States Department of Agriculture Food Safety and Inspection Service FSIS Initiatives for Listeria monocytogenes • FSIS target: 0.70% contamination rate (preliminary 2007 rate=0.37%) • Risk assessments revealed that deli meat and hot dogs were greatest risk among FSIS-regulated products • Risk assessments also showed the benefits of industry mitigations, adding growth inhibitors, antimicrobials or other post-lethality treatment to ready-to-eat products that may be exposed to Listeria in the environment • Pathogen testing became risk-based, factoring past testing, volume of production, use of interventions, and product risk • Recent study suggests that cross-contamination in retail delis may be a significant source of Lm contamination United States Department of Agriculture Food Safety and Inspection Service FSIS Initiatives for Campylobacter • Lab methodological problems delayed our ability to establish a performance standard or begin a regulatory program • Baseline testing in broiler chickens currently underway— Campy historically associated with chicken exposure • Once complete the agency will establish performance standards or guidelines for industry to meet • Industry interventions for Salmonella expected to be effective against Campylobacter United States Department of Agriculture Food Safety and Inspection Service Other FSIS Initiatives • Hosted attribution public meeting in April 2007 • Hosted public meeting on non-O157 STEC in October 2007 • Hosted public meeting April 9-10 on STECs • Will host public meeting May 15 on improving communications/collaborations during outbreak investigations • New investigations directive to be released, regarding how FSIS investigates foodborne illness linked to regulated products, the type of evidence collected and how it is judged • Strengthened PulseNet and VetNet database linkage • Development of public health-based performance measures United States Department of Agriculture Food Safety and Inspection Service Re-assessment—Case Study #1 • Outbreak of E. coli O157:H7 associated with frozen steaks in 2003 – 7 cases of illness – Steaks sold door-to-door – Traceback to producer revealed these steaks were tenderized/marinated – Food Safety Assessment conducted; injection equipment disassembled weekly – Recall of one week’s production of beef products United States Department of Agriculture Food Safety and Inspection Service E. Coli case, continued FSIS Regulatory Policy Response Federal Register Notice published 5/26/05 • Cited 3 outbreaks in 2000, 2003, 2004 and total of 17 cases associated with exposure to tenderized beef products • The FR Notice announced that: • Plants producing such products should reassess their HACCP plans during their annual reassessments to consider whether E. coli O157:H7 is a hazard reasonably likely to occur • Plants should consider purchase specifications for source products treated to minimize E. coli O157:H7 • Plants should consider use of antimicrobial treatments prior to tenderizing United States Department of Agriculture Food Safety and Inspection Service E. Coli case, continued • Collaboration with FDA to develop guidance for retailers for incorporation into the Food Code • Development of FSIS compliance guidelines • Consideration of labeling changes and need for higher temperature for cooking • FSIS inspection personnel recently surveyed the industry to determine the extent and nature of HACCP reassessments United States Department of Agriculture Food Safety and Inspection Service E. Coli case, continued • Request for FSIS Office of Public Health Science (OPHS) to consider collecting data on prevalence of this pathogen in these products (in collaboration with Agricultural Research Service) • Request for OPHS to update its risk assessment on E. coli O157:H7 in non-intact beef products • There were 3 more outbreaks related to nonintact beef products in 2007 United States Department of Agriculture Food Safety and Inspection Service Re-assessment—Case Study #2 • Salmonellosis associated with frozen stuffed raw poultry products – Illnesses in 2005 linked to breaded, frozen chicken entrees – FSIS issues a public health alert reminding consumers that these products contain raw poultry, though the breading has been browned, that microwave cooking can be inconsistent, and these products should be cooked to 165o F internal temperature – FSIS asked the National Advisory Committee on Microbiological Criteria for Foods (NACMCF) to recommend a safe cooking temperature for poultry United States Department of Agriculture Food Safety and Inspection Service Salmonellosis case, continued • More cases of salmonellosis linked to similar products reported in early 2006 • Investigations showed that some of the illnesses were associated with products from one specific producer – PFGE matches between patients and food products – Food histories of cases confirmed exposures • FSIS requested a recall of a lot of frozen stuffed chicken entrees • FSIS issued a letter to the industry and then labeling compliance guidance requiring label changes: – Wording changes to emphasize that the poultry is raw – Need to validate cooking instructions United States Department of Agriculture Food Safety and Inspection Service Salmonellosis case, continued • NACMCF issued report indicating that 165o F was an effective temperature for consumers to ensure safe poultry; that microwave preparation of stuffed poultry products could be used safely • FSIS learns of new cases of salmonellosis associated with these products • FSIS issues another public health alert but no further recalls • New labels required by November 1, 2006 United States Department of Agriculture Food Safety and Inspection Service Salmonellosis case, continued WASHINGTON, March 29, 2008 - The U.S. Department of Agriculture's Food Safety and Inspection Service (FSIS) is issuing a public health alert due to illnesses from Salmonella associated with frozen, stuffed raw chicken products that may be contaminated with Salmonella. United States Department of Agriculture Food Safety and Inspection Service Illness Investigation Objectives • • • • • • Verify the association Identify the source of production Prevent further exposures of consumers Initiate regulatory action (when indicated) Identify contributing factors Prepare an internal summary and lessons learned United States Department of Agriculture Food Safety and Inspection Service Step 1: Human Health Surveillance • Ongoing disease surveillance conducted by – Local, State and Territorial health departments – CDC • Ongoing monitoring of foodborne disease reports by FSIS – PHELs in Omaha and Atlanta – FSIS liaison to CDC in Atlanta United States Department of Agriculture Food Safety and Inspection Service Step 2: Illness Reported; FSIS Product Suspected • FSIS receives epidemiologic data from other public health agencies • FSIS judges the strength of the association using recognized criteria – temporal sequence; biological plausibility; specificity; dose response; relative risk/odds ratio • FSIS determines that further action is necessary United States Department of Agriculture Food Safety and Inspection Service Step 3: FSIS Begins Investigation • Traceback and Traceforward • Microbiological Results – Product – Clinical – Environmental • In-plant Food Safety Assessment United States Department of Agriculture Food Safety and Inspection Service Product Traceback Investigations: What We Need to Know • Who? – Producing establishment number • What? – – – – Name and type Lot number Product code Product weight and units per case – Percent lean • When? – Production code – Sell by/use by date • Where? – Amount of product purchased – Purchase date – Point of purchase, including name and complete address Is there any left over product held by consumer? Packaging? Are there other sources of the same product? United States Department of Agriculture Food Safety and Inspection Service Step 4: FSIS Analysis of Available Data • Is the epidemiologic evidence consistent with: – – – – microbiological data? traceback investigation? environmental evaluation? in-plant findings? United States Department of Agriculture Food Safety and Inspection Service EPIDEMIOLOGY TRACEBACK MICROBIOLOGY FOOD SAFETY ASSESSMENT United States Department of Agriculture Food Safety and Inspection Service Step 5: FSIS Regulated Product Implicated • Considerations for Agency action: – – – – – – the pathogen and severity of illness population at risk whether new cases are being reported strength of the epidemiologic data strength of laboratory data investigation at point of purchase and/or preparation United States Department of Agriculture Food Safety and Inspection Service Step 6: Agency Action • The Agency considers requesting a recall or detaining and seizing product in accordance with the Acts • The Agency considers a public health alert to advise about potentially adulterated product not subject to recall (i.e., not in commerce) United States Department of Agriculture Food Safety and Inspection Service Step 7: FSIS Assessment of the Investigation & Lessons Learned • An internal summary documents the investigation, findings, and recommendations • Lessons learned generated by those involved in the investigation United States Department of Agriculture Food Safety and Inspection Service Recall Defined A firm’s voluntary removal of distributed meat, poultry, or egg products from commerce when there is reason to believe they are adulterated or misbranded under the FMIA, PPIA or EPIA United States Department of Agriculture Food Safety and Inspection Service Recall Process • Problem Identification: – The company finds the problem – FSIS microbiological sampling – Information from in-plant inspection program personnel – Epidemiological data gathered by Federal or State Agencies – Consumer complaints United States Department of Agriculture Food Safety and Inspection Service Why Recall? A Recall is a fast and effective method of removing distributed products, particularly when many lots of product have been widely distributed. United States Department of Agriculture Food Safety and Inspection Service Who Recalls? • Manufacturers and distributors of product • FSIS does not have, and is not seeking, mandatory recall authority United States Department of Agriculture Food Safety and Inspection Service However • FSIS may initiate the recall process by informing a firm that adulterated product has been identified in commerce • FSIS retains the right to detain or seize product to protect consumers United States Department of Agriculture Food Safety and Inspection Service Food Safety and Inspection Service United States Department of Agriculture www.fsis.usda.gov