Meeting the F.S.A. challenge

by Bernard Shire
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WASHINGTON — When President Obama’s Food Safety Working Group announced this summer a plan to upgrade the Food and Drug Administration’s food safety efforts, the U.S. Department of Agriculture’s Food Safety Assessments (F.S.A.) program already had been in operation for several years. The efforts outlined by the F.S.W. are similar to those currently in place within the U.S.D.A.’s Food Safety and Inspection Service.

Secretary of Agriculture Tom Vilsack, Vice-President Joe Biden, and Health and Human Services Secretary Kathleen Sebelius recommended at a press conference a new, public health-focused approach to food safety based on three core principles: prioritizing prevention, strengthening surveillance and enforcement and improving response and recovery. The U.S.D.A.’s F.S.A. program, and its companion program called Intensified Verification Testing, is carried out in meat and poultry plants by officials known as Enforcement, Investigations and Analysis Officers (E.I.A.O.s). These are the successors to the former F.S.I.S. compliance officers, who focused not so much on inspection of food safety in meat plants, but on making sure plant operators complied with any enforcement penalties handed down by the agency.

The purpose of an F.S.A. is to do an extensive investigation of a plant’s food safety system whenever an F.S.I.S. sample tests positive for E. coli O157:H7, Listeria monocytogenes generally in ready-to-eat products, Salmonella, when an F.S.I.S. sample of raw beef tests positive for E. coli, when another government agency finds any of the above in a plant, or when a plant’s inspectors document repetitive occurrences of noncompliance in the establishment’s Lm control program.

Food Safety Assessments pose significant challenges for meat and poultry plants, especially for small businesses. And now, the U.S.D.A. announced in a just-released directive and notice, it is intensifying both programs, to comply with the F.S.W.’s direction for food safety.

The F.S.I.S.’s directive states the agency will now put meat and poultry processing and slaughter plants into a priority level for F.S.A. scheduling based on public health criteria, in addition to traditional event-based scheduling. Any plant meeting one or more of the criteria will be visited by the U.S.D.A. "for cause" F.S.A. A "for cause" F.S.A. is one prompted by a positive sample result, production and shipment of adulterated product "or any other high-priority food safety-related incident," according to the agency.

But according to the U.S.D.A.’s "top priority" listing for F.S.A.s, a wide variety and number of plants are likely to receive visits from the F.S.I.S. Not only will they include sole suppliers of ground beef or patties or raw beef components with a positive E. coli O157:H7 sample, plants having an F.S.I.S. or other government test resulting in a positive E. coli, Lm or Salmonella sample are also included. They also will include plants with a history of health-related noncompliance records, plants whose F.S.I.S.-regulated products were linked to human illness, who had positive Salmonella in heat-treated, not fully cooked, not shelf-stable poultry products, plants who experienced any kind of HACCP or sanitation enforcement action, including an enforcement letter — and plants shipping product that underwent a Class I or Class II recall.

Also to be included in the top priority are plants having an F.S.I.S. positive sample of Lm, Salmonella or E. coli O157:H7 in ready-to-eat products or a positive Lm food-contact surface sample.

Plants in a slightly lower priority, but still to receive F.S.A.s, include: those tested for Salmonella that are above standard; plants changing production processes in the F.S.I.S.’s view may impact public health; and plants that experienced consumer complaints about their products reported through the Consumer Complaint Monitoring System. New establishments just beginning to operate under inspection would also likely receive an F.S.A.

Outside of these priorities, routine but comprehensive F.S.A.s for no cause at all, are to be conducted in plants at least every four years.

Needless to say, these intensifications of the F.S.I.S. in-depth evaluations of plant food-safety programs pose new challenges to meat and poultry slaughtering and processing plants. But for very small and small plants and even medium-size plants, often under the weight of multiple HACCP plans and food-safety interventions they carry out because of the large number of products many of them manufacture, the new U.S.D.A. policies will be even more of a challenge — and even a greater threat to their survival. FSM

Bernard Shire is a contributing editor to Meat & Poultry, a sister publication to Sosland Publishing’s Food Safety Monitor. He works as a food safety consultant and writer for Shire & Associates. This story originally appeared in the October issue of Meat & Poultry.

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