McCutcheon, John W.

English

Research Papers in Economics

Agricultural Outlook Forum                                 For Release: Monday,
February 23, 1998
HACCP AND MEAT AND POULTRY INSPECTION
John W. McCutcheon
Associate Deputy Administrator, Field Operations
Food Safety and Inspection Service, USDA
Good morning.  My name is John McCutcheon, and I am the Associate
Deputy Administrator of Field Operations, of the Food Safety and Inspection
Service (FSIS), U.S. Department of Agriculture.  FSIS is the federal Agency
responsible for ensuring the safety, wholesomeness, and accurate labeling of
meat, poultry, and egg products.
It's a pleasure for me to be here today.  I've been asked to tell you about the
Hazard Analysis and Critical Control Point, or HACCP system, as it relates
to meat and poultry inspection.
This is an exciting time for us.
Before doing so, however, I'd like to take a few moments to describe recent
developments in the Administration's Food Safety Initiative.
FSIS operates under the authority of the Federal Meat Inspection Act, the
Poultry Products Inspection Act, and the Egg Products Inspection Act.  FSIS
sets standards for food safety and inspects meat, poultry, and egg products
produced domestically and imported.  Our mission is to protect the public
health and safety.
Recently, we have broadened our food safety strategy to cover the entire
farm-to-table continuum.  Much of the support for our efforts has come from
the White House, under President Clinton's Food Safety Initiative.  The
initiative focuses on six major areas:  1)  the development of a nationwide
early-warning system for foodborne illness; 2)  improvement in risk-
assessment capabilities through an interagency consortium, that will
coordinate and guide overarching Federal risk assessment research related to
food safety;  3)  development of new research methods to detect the presence
of pathogens in food, enhance our understanding of how pathogens become
resistant to food-preservation techniques and antibiotics, and develop new
technologies for the prevention and control of pathogens; 4)  improvement
of inspection and compliance by agencies responsible for food safety,
including greater use of HACCP; 5)  development of a public-private
partnership to develop and encourage dissemination of standard food safety
messages; and 6)  initiation of long-range strategic planning to address public
health, resource and management questions facing Federal food safety
agencies.The President directed the USDA, Health and Human Services (HHS), and
the Environmental Protection Agency (EPA) to consult with all interested
parties to identify and report on specific steps to improve the safety of the
food supply, and to ensure it remains the safest in the world.  Two public
meetings were held to solicit input from States, consumers, producers,
industry, universities, and the public.  The final report, released May 12,
1997, reflects the interactive process.  It outlines steps USDA, HHS, and
EPA will take to reduce foodborne illness.
These more recent developments build on our earlier efforts in this arena that
have already come to fruition with the publication of our landmark rule on
Pathogen Reduction and HACCP Systems, on July 25, 1996.  This rule is the
centerpiece of our new regulatory approach and will enable us to step
confidently into the 21st century.  The rule mandates HACCP, sets certain
food safety performance standards, establishes testing programs to ensure
that standards are met, and assigns new tasks to inspectors to enable them to
ensure regulatory performance standards are met.  The final rule applies to
6,500 federally inspected and 2,550 state inspected slaughter and processing
plants in the U.S., as well as to countries who export meat and poultry
products to the U.S.  Although egg products are not covered by the rule, yet,
we have developed a strategy, including HACCP, to improve the safety of
eggs and egg products.  We'll extend this system to cover eggs, eventually.
What is HACCP?  HACCP is a process control system designed to enable
industry to identify and prevent microbial, chemical, and physical hazards in
food production, and correct deviations as soon as they're detected.  It is
based on the premise that the logical and proven way to ensure safe food and
prevent problems is to control the process from beginning to end, rather than
detecting problems at the end of the line.  HACCP is comprised of 7 steps:
1) Hazard analysis; 2) Critical Control Points; 3) Establishment of Critical
Limits; 4) Monitoring Procedures; 5) Corrective Actions; 6) Record Keeping;
and 7) Verification Procedures.
Under the new rule, businesses that produce food are accountable for its
safety.   They need to maintain control over their systems for sanitation,
sanitary dressing, and food processing.  They need to ensure their systems
include established procedures to prevent, eliminate, or reduce to an
acceptable level hazards that may occur.  To accomplish this, all plants must
develop and implement a HACCP plan for each process, and conform to the
principles of HACCP.  
This is not a "one-size-fits-all" approach.  Rather, each plant designs its own
plan to meet USDA regulatory requirements.  Each plan must be transparent
and self-contained.  The plans are required to address those Critical Control
Points (CCP's) that affect product safety as opposed to those related to
economic adulteration, labeling, or quality concerns.  Other inspection
measures remain in place to address those areas.  This is regulatoryreinvention in action.
HACCP implementation is occurring in phases, to take into account plant
size.  The largest plants,  those with 500 or more employees, were required
to have HACCP systems in place by January 26, 1998.  These plants account
for about 75% of slaughter production and 50% of processed product
production.  Small plants, those with 10 or more employees but fewer than
500 employees, are required to implement HACCP by January 25, 1999.
Very small plants, those with fewer than 10 employees or annual sales of less
than $2.5 million, are required to implement HACCP by January 25, 2000.
As of February 4, 1998, HACCP has been implemented in 297 large plants
throughout the U.S.  Over 2000 inplant (FO) personnel have undergone
extensive HACCP training.  Based on reports from across the country, the
training has been extremely effective, and has enabled inspectors and
supervisors to carry out their oversight responsibilities with even greater
detail and scrutiny than in the past.  Inspectors are verifying that HACCP
plans conform with regulations, verifying how the plants are carrying out
their hazard prevention and sanitation responsibilities, documenting failure
to meet regulatory requirements, and enforcing regulations when a plant is
not in conformance with regulatory requirements.  
Prior to conducting any verification activities, FSIS inspectors participate in
a plant awareness procedure.  FSIS initiated this procedure, whereby
inspection personnel meet with plant management and develop a working
understanding of each plant's HACCP plan.  This plant awareness procedure
has facilitated communication between plant management and inspection
personnel concerning how the HACCP system was designed to function in
each facility.  When questions have arisen, our Technical Service Center in
Omaha, Nebraska has played a strategic role in support of FSIS personnel.
USDA inspectors will continue to be present every day in plants, to verify a
plant's compliance with its HACCP plan, and take direct action when
necessary.  Our inspectors have lost no authority on the production line.
They continue to have authority to take action to ensure that establishment
HACCP systems can produce product that meets food safety regulations, and
to assure that affected product is disposed of properly.
Enforcement
As a logical nexus, the changing roles of the regulated industry and
inspection have stimulated changes in the compliance functions of FSIS.  The
conceptual shift from government to industry and overall pro-active approach
to food safety and process evaluation has enhanced the importance of an
effective enforcement program.  Our new inspection system has been
strengthened by integrating the work of our inspectors with our ComplianceStaff.  This enables FSIS to use a team approach to plant enforcement actions
and to respond quickly to situations, to determine whether corrections have
been effective.
When HACCP or sanitation system failures occur, compliance officers assist
inspectors by reviewing documentation of failures of plant control systems
and help ensure appropriate due process when enforcement actions are
needed.  This includes suspending the use of inspection marks, suspending
or withdrawing inspection, or holding suspensions in abeyance, and closing
plants.
While Pathogen Reduction and HACCP regulations provide the industry with
enormous flexibility to develop and implement innovative measures for
producing safe foods, they also impose clear and unequivocal responsibilities
for preventing contamination by pathogens and other hazardous substances.
Industry is accountable for food safety.  This means that inspectors and
compliance officers must now verify industry practices and take enforcement
actions when a plant's control systems fails to meet regulatory requirements.
Essentially, with HACCP, FSIS has linked a plant's ability to control
processes and the eligibility of their products to bear the marks of inspection.
If a plant cannot demonstrate the effectiveness of its system, a withholding
action will be issued, which could lead to a formal action to withdraw
inspection, permanently.
We are committed to a systematic process to ensure safe food for consumers.
HACCP provides us with tools to stop operations where there is a pattern of
repetitive deficiencies, and insist on preventive measures to improve food
safety before a plant can reopen.  Meat and poultry plants must therefore
continually and consistently demonstrate to FSIS inspectors that product is
not adulterated, and that plant sanitation and process control systems prevent
adulteration.  They must also demonstrate truthful and accurate record-
keeping.  They need to verify that their control measures have worked, and
that their products are safe and wholesome.
Where We're Going: Inspection Reform
Although we have made significant progress with HACCP and other aspects
of the Pathogen Reduction rule, we are committed to continuing to improve
our traditional inspection program for meat and poultry, and continuing to
address other areas of food safety in the farm-to-table continuum.  Changes
in inspection methods and focus will benefit us all.   However, the
PR/HACCP rule is not the end of the line; there's still a lot for us to do.  I'd
like to now share some of our new initiatives with you.
First, we plan on continuing to improve our inspection system throughexperimentation with new models for in-plant slaughter inspection.  These
models will provide the same level of protection, but allow some inspection
resources to be reallocated to food safety tasks off-line in slaughter plants,
to new food safety tasks in processing plants, and during the distribution of
meat and poultry products once they leave the plant.
The HACCP-based Inspection Models Project will describe for slaughter and
slaughter processing plants that have implemented HACCP, what alternative
inspection models FSIS could use that would enhance food safety
accountability and maintain the other consumer protection accomplishments
of the present system.  Today, plants must develop HACCP systems around
our ante and post mortem inspection stations.  Plants participating in this
project will be able to develop HACCP through all aspects of the production
system, including those presently constrained by our inspection activities.
In other words, we would still perform carcass-by-carcass examinations, but
how we do the examinations may differ.
Second, we are interested in systematically focusing on conditions and
practices during distribution that may contribute to the growth of pathogens.
"In-distribution" aspects of food safety include transportation, out-of-plant
locations, storage, commercial kitchens, retail stores, restaurants, hotels, and
other institutions.  These are vital links in the farm-to-table food safety
continuum.  With regard to transportation and storage of meat and poultry
products after they leave the FSIS inspected plant, we believe the federal
government has a responsibility to set standards regarding such inspection
matters, and we have been working with FDA on this issue.  
Regulatory requirements for in-distribution food safety may focus on
meeting time and temperature requirements.  These, combined with in-plant
regulatory requirements for zero fecal contamination, form the foundation of
a system that produces safe and wholesome food.  We are currently
examining the relationship between in-plant and in-distribution regulatory
requirements and enforcement locations, to see how we can most efficiently
and effectively redeploy our resources from areas of other consumer
protection, to focus on food safety, ensure standards are met, and to assure
that the public gets the maximum return from its investment in food safety.
Third, we are concerned that small and very small companies that are
scheduled to implement HACCP in 1999 and 2000 have the necessary
technical guidance to help them prepare for implementation.  As part of our
Small Plant Demonstration Project, we have recently announced the
availability of thirteen generic HACCP models to serve as guides in
developing plant-specific
HACCP plans at the lowest possible cost.  These models are roadmaps for
developing HACCP plans.
In addition, we're in the process of revising two publications: "Guidebook forPreparation of HACCP Plans," and the "Meat and Poultry Products Hazards
and Control Guide."  These two publications were reissued for public
comment, along with HACCP Model Plans.  The public comment period has
closed and we're in the process of considering the comments prior to
revision.  
And finally, fourth, we are looking at passing new regulations.  For example,
we published our "Proposed Rules of Practice" in the Federal Register, just
last month. (January 12, 1998)  These proposed rules are intended to
supplement existing rules of practice, but clarify the responsibilities of a
plant regarding refusal, suspension, or withdrawal of inspection services
when the Agency determines that a plant's HACCP systems are inadequate
or ineffective, or a plant is not meeting other regulatory requirements
associated with the PR/HACCP rule.  In addition, the Clinton Administration
has asked Congress for authority to fine companies for violations of food
safety standards.
Conclusion:
In conclusion, inspectors will become more important in the FSIS of the
future, albeit their jobs will most likely differ somewhat from what they
perform today.  The cooperative relationships we're forging with other
federal agencies, state and local governments, consumers, and the industry,
in addition to the new roles our inspectors are playing, we believe, will lead
to a safer food supply.  Accountability and responsibility are key in these
efforts.  
These philosophies extend beyond our domestic borders.  Any government
exporting meat and poultry products to the United States will be required to
meet our standards.  A foreign country must demonstrate the equivalency of
its inspection program before its products will be allowed into the U.S.
HACCP provides a logical and science-based framework for a food safety
regulatory system in which inspection, enforcement, and technological
resources are targeted to the most significant food safety hazards.  In
conjunction with regulatory reform and reorganization to deploy available
resources efficiently and effectively, HACCP presents us with a "win-win"
situation.  For consumers, HACCP implementation means safer food and less
foodborne illness.  For animal producers, HACCP implementation provides
you with new opportunities to provide cleaner and safer livestock and poultry
to the food processing sector.  Finally, for regulated industry, HACCP
implementation means you have the opportunity to prove your commitment
to and accountability for providing the safest food in the world.
We know there is no silver bullet that guarantees food safety, and that
consumers must remain vigilant and continue to follow safe meat and poultry
handling labels and practices.  However, this new system is a victory forAmerican consumers, and we at FSIS are committed to making HACCP
work.

HACCP AND MEAT AND POULTRY INSPECTION

Abstract

Similar works

Full text

Available Versions

Research Papers in Economics