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Food Safety: A Global Perspective
Food Safety: A Global Perspective RICHARD H. FORSYTHE Arkansas Research Management, Inc., Fayetteville, Arkansas 72702 instituted at this time. The role of research, regulatory reform, and political science is considered as supportive of food service and consumer education. Education of food service workers, institutional employees, and consumers is a responsibility that the land grant universities should take very seriously. Networking with associations like the National Restaurant Association and its regional affiliates will be invaluable in improving the health of the people of the U.S.
(Key words: food safety, inspection, education, research, regulation) 1996 Poultry Science 75:1448-1454
I was honored when the Program Committee asked me to present the World Poultry Science Association (WPSA) lecture, first because of my long association with WPSA, but more importantly because it presented an opportunity to take a serious look at the current status of the safety of our food supply, particularly, the safety of poultry and eggs. When I chose the topic "Food Safety: A Global Perspective", I was thinking beyond an "International Perspective" because the invitation and may choice of the topic came well before the Bovine Spongiform Encephalopathy (BSE) episode in the United Kingdom and its possible relationship with Creutzfeldt-Jakob disease (CJD) in humans, the Russian criticism of the U.S. poultry inspection system, and the subsequent proposed ban on poultry exports. Because these activities are part of the politics of food safety, I will have some further comments later. I was actually thinking of "global" in a more "universal" sense. "Global," means the entire food system, as in the current catchy phrase "farm to table", includes farm production, processing, marketing, and distribution, restaurant and institutional food service, and home preparation. And "global" encompasses the infrastructure of the system, which includes food research and product development, regulation, inspection and quality assurance, risk assessment, legislative or political input, education and extension, the media, and last, but certainly not least, consumer groups. Most particularly,
Received for publication July 11, 1996. Accepted for publication August 2, 1996.
"global" includes the health and well-being of the American people. In the next few minutes, I will review the status of the food safety agenda of some of these entities (agencies), and how they will contribute not just to safe food, but to a healthier population. Because many of this audience are researchers, let's look first at research. A government Food Safety Research Workgroup report An Overview of Federal Food Safety Research, Including the Research Needs for the Future from the Committee on Food, Agricultural, and Forestry of the Federal Coordinating Council for Science, Engineering, and Technology was published in January 1993 (Acker, 1993). In her transmittal letter Chairperson, Dr. Catherine W. Carnevale stated "The Food Safety Research Workgroup members recognized that the character of the food supply is changing. New sources of food, natural and synthetic, as well as increasing imports, present food safety regulators with new challenges and concerns. Furthermore, increased trade in food worldwide has led many countries to seek assurance that products meet their country's safety requirements. Food safety concerns have become global, necessitating that food safety research be approached from a global perspective." This report documents that 21 federal agencies spend about 200 million dollars per year on food safety research under approximately 50 laws that directly or indirectly authorize such research. The departments carrying out food research included in the report were Agriculture, Health and Human Services, National Institutes of Health, Commerce, State, Defense and the Environmental Protection Agency (EPA). These departments, which spent the $200 million plus for food safety research, also spent over $12 billion for what they called
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ABSTRACT The health of the population of the U.S. is affected by many factors, not the least of which is its food supply. A major source of high quality animal protein comes from poultry, eggs, and meat. The major effect of personal habits and the environment, diet, tobacco, alcohol, are considered, along with the microbiological effect on foodborne illness and health. The inspection system for meat and poultry is reviewed, in light of the publication of significant revisions being
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Although admittedly, it is a very rough estimate, based on the federal investment of $200 million, and state and industry matching data based on the Food Safety Consortium experience, we can estimate that at least $400 million in research and technology development is spent annually in the U.S. This amount is a rather small part, actually less than 0.1%, of the $647 billion we spent for food in the U.S. in 1994, of which over 45% was spent away from home (Manchester and Clausen, 1995). This expenditure on research really does not seem like a major global effort! We are able to determine a cost:benefit ratio of many agriculture research activities. For example, Dr. Robert Evenson, Professor of Economics at Yale, reported that agriculture research in South Carolina returned $12 for each dollar invested (Evenson, 1989). In a personal communication with Dr. Evenson, he thought that realistically for the country the return might be nearer $4 to 5. The effect of research in reducing costs can be documented in many cases. For example, if, through genetic research, we could increase broiler breast meat by 1%, and if we applied that to only 20% of the Arkansas broilers, their value would be increased by over $10 million. Unfortunately, we have been unable, to develop similar hard data for the return on investment in food safety research. President Clinton, in 1993 (Clinton, 1996), established the cabinet-level, National Science and Technology Council (NSTC) to coordinate science, space, and technology policies across the federal government. Recognizing that the health and well-being of Americans was central to the President's strategy, NSTC and the Office of Science and Technology Policy of the Executive Office of the President convened a forum at the National
Academy of Sciences in late 1994 that addressed questions fundamental to America's health and wellbeing. The policy document resulting from this forum, Meeting the Challenge—A Research Agenda for America's Health, Safety and Food, was published in February, 1996 and identified four common themes cutting across all priority issues. These were: 1) Health, Safety, and Food Research, 2) Prevention, 3) Communication, and 4) Education. In the document, Phil R. Lee, M.D., Assistant Secretary for Health, Health and Human Services stated "From a health standpoint, there is no question that the money invested in science over the past five decades has been very well spent. Americans are living longer, better and since the turn of the century, one should note that the average life expectancy has increased from 47 to 75 yr." Poultry scientists have contributed significantly to this research and would do well, along with their administrators and funding sources, to use this report to justify their requests for funding. Research expenditures are not the only, and actually probably are only a minor part of the cost of ensuring that safe food is supplied to consumers. The major public regulatory costs of food safety programs are in the Food and Drug Administration (FDA), which is responsible for all food other than meat and poultry, and the Food Safety Inspection Service (FSIS) of the Department of Agriculture, which is responsible for meat and poultry. The FDA projected Fiscal year (FY) 93 budget was just under $800 million. The FSIS budget for that same year was just under $500 million. These two regulatory costs of $1.3 billion, are still less than 0.2% of the value of the food at the consumer level. Also included in the FSIS budget is the cost of almost 8,000 inspectors in over 6,200 federally inspected meat and poultry plants, who at best can reduce visual defects, which result in partial or whole bird condemnation. Condemnation rates are consistently less than 3 birds out of every 100. It is hard to imagine looking at so many birds! This organoleptic inspection system is in serious need of overhaul and has been the subject of critical review by USDA, industry, and consumer groups since early 1993, when there was an outbreak of Escherichia coli 0157:H7 in children eating undercooked hamburgers on the west coast. It should be pointed out that this review process did not start with Mike Espy or Dan Glickman, or Bill Clinton. This review started in late 1983, when FSIS asked the Food and Nutrition Board (FNB) of the National Research Council to evaluate the scientific basis of the current system for inspecting meat and poultry (Food and Nutrition Board, 1985). This Committee Report issued in 1985 recommended that FSIS intensify its current efforts to control and eliminate microorganism contamination that causes disease in humans. These efforts were to include evaluation of rapid diagnostic procedures for detection, and education of the general public, health care personnel, educators, and extension service workers in the safe handling of meat and
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"other" research, committing less than 2% of federal research dollars to research on the safety of our food supply. How global is federal food safety research? Developing an estimate of financial resources from state and private funding is much more difficult. In the three-state Food Safety Consortium (Iowa State, Kansas, and Arkansas) our goal was to exceed a match of $1 for every $1 of federal funding. The Consortium consistently exceeds that goal. Data on research support from private industry, other than that tunneled through trade o r g a n i z a t i o n s is g e n e r a l l y n o t available. The Southeastern Poultry and Egg Association invests over $1 million/yr, and currently has 85 projects being funded, an investment in research of almost $3 million. Although not all of this investment relates to egg and poultry product safety, a significant effort of public and private scientists is devoted to improving the safety of our products. Other trade associations, including the National Turkey Federation, the National Broiler Council, the Pacific Egg and Poultry Association, the Midwest Poultry Association, the United Egg Producers, and many state and regional associations contribute significantly to the research effort through continuing contact with both federal and state funding agencies to emphasize research needs.
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poultry. The Committee also recommended "that means be found for FSIS to coordinate the control and monitoring of hazardous agents during production, where those agents enter the food supply." Sounds like "farm to table". The Committee also recommended "that the precepts of risk assessment be included in any modifications of the inspection system. The Committee considered, at FSIS's specific request, to explore whether bird-by-bird inspection might be modified, but it recommended that before the traditional inspection be changed, a comparative risk analysis of any new inspection technology and the traditional system be conducted. This analysis has never been done!
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Immediately upon the issuance of that report, the FSIS Administrator requested that the National Research Council conduct a follow-up study, specifically for poultry (Food and Nutrition Board, 1987). "The committee concluded, in agreement with the earlier Committee...that FSIS should consider using risk-assessment techniques to manage and control poultry associated hazards." The Committee developed several risk-models in which flow charts with potential hazardous activities were identified, the magnitude of the health risk was accessed and the critical factors were identified that might influence the magnitude of the risk. From this beginning, in 1987 the hazard analysis and critical control point (HACCP) approach (Buchanan, 1990), earlier developed by a team at the Pillsbury Company as a means of assuring the safety of foods produced for the U.S. space program, was introduced to FSIS. The National Advisory Committee on Microbiological Criteria for Food (Committee, 1992), a group of distinguished public and private scientists, established that HACCP is a systematic approach to food safety consisting of seven principles. Briefly these seven principles are: 1) conduct a hazard analysis, 2) identify Critical Control Points (CCP), 3) establish CCP limits, 4) establish monitoring requirements, 5) establish corrective actions, 6) develop record-keeping procedures, and 7) develop procedures for verification that the system is working. Although the HACCP system has been widely discussed, these principles have never changed. Following innumerable workshops, public hearings, seminars, congressional hearings, conferences, and "false starts", the "war on pathogens" was joined when Secretary Mike Espy in late 1993 commissioned the USDA Pathogen Reduction Task Force (PRTF) "to provide leadership, coordination and oversight of the Department's programs to ensure a safe and wholesome meat and poultry food supply." On February 3, 1995, FSIS (FSIS, 1995) published the long-awaited proposed rule to modify, add to, or eliminate portions of the regulations for the inspection of meat and poultry. According to Michael Taylor (USDA News Release, February 1,1995), acting under secretary for Food Safety and administrator of FSIS: "These proposals mark a fundamental shift. They are targeted to improve the safety of meat and poultry products directly by
addressing the pathogenic microorganisms that cause most food-related illnesses and by increasing our ability to ensure that all meat and poultry companies follow sound food safety procedures." The first part of this statement was directed toward microbiological standards and the second part to HACCP. One of the most controversial parts of the proposed rule has been the requirement for Salmonella testing. Time and space do not permit a review of the thousands of pages of comments from every trade association, many consumer advocate groups, the inspectors union (National Joint Council of Food Inspection Locals), the media, and academic science professionals. To believe that partisan politics did not play an important role in these discussions would be naive! The Institute of Food Technologists (Disser, 1996) submitted comments that included "There is no question that we need to move to a science-based system for inspecting meat and poultry. That doesn't mean, however, that randomly testing raw meat and poultry for pathogens is the best way to reduce bacterial contamination." Michael Taylor stated early this year in Atlanta "FSIS hopes to publish a final rule early this year" (Bowers, 1996). As these remarks were being prepared in early June, 1996 the HACCP final rule had gone to the Office of Management and Budget. On July 6, 1996, President Clinton announced that the rule had been finalized and would be published in the Federal Register within a few days. An advance copy was distributed to trade associations in Washington on Monday, July 8, 1996. Microbiological performance standards are included in the rule. H. Russell Cross, the Executive Director of the International Meat and Poultry HACCP Alliance commented (Bowers, 1995) that no one has the data to set any level of bacterial standard "The reason is that we don't have the infectious dose data to do any kind of a risk analysis, so any number we pick will be arbitrary." Cross says that USDA should conduct continual baseline surveys of key pathogens to provide a yardstick for industry to determine if it is making progress over time. It would appear that others in the Small Business Administration (SBA) and the Office of Management of the Budget (OMB) agreed with Dr. Cross, and attempted to change the microbiological testing requirements, thus delaying the issuance of the final rule, but without success! The food industry, including most poultry companies in the past decade have moved from a concept of Quality Control, in which a battery of inspectors looked for defects and then rejected those products failing to meet standards all through the processing system, to Quality Assurance, in which Good Manufacturing Practices, many including the HACCP principles, are designed to manufacture products without defects and have significantly reduced or eliminated the need for inspectors. Make it right the first time! This is the religion of Dr. Edward Deming, who turned manufacturing systems around, first in Japan, and then in the
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Elimination of tobacco use would prevent over 400,000 deaths; and diet and exercise would prevent 300,000 deaths. Since the 1970's: stroke death rates have declined by 58%, coronary heart disease has dropped by 49%, and tobacco use among adults has declined form 34% to 25%.
The report goes on to estimate the costs of these serious illnesses, chronic disabilities, and premature
deaths, i.e., heart disease and stroke cost $135 billion annually, alcohol abuse costs $98.6 billion, and tobacco abuse costs $65 billion. Three major measurable goals were identified. Goal 1. Increase the span of healthy life. That portion of ones life with few limitations of major life activities, in 1990, 64 yr of a total 75.4 yr life expectancy, i.e., 11.4 yr of unhealthy or limited life activities. Goal 2. Reduce health disparities among Americans. Blacks had healthy life expectancy of 69.1 total yr, compared to whites, 76.1 yr, and a healthy life of 56 yr. Goal 3. Achieve access to preventative services for all Americans. Seventy-seven percent of people under 65 yr had private insurance in 1986, only 71.9% had it in 1992, a very serious decline. Although food and drug safety were not included as a separate category in 1990, it was discussed in the 1995 update. The rate of Salmonella infections was targeted for 16 per 100,000 for 2000, but in 38 states, the rate was below the target, actually exceeding the goal by 200%. Salmonella enteritidis outbreaks were reduced from 77 in 1989 to 63 in 1993, demonstrating the effectiveness of the S. enteritidis Prevention Programs in Pennsylvania and elsewhere. The 1995 report update report should be carefully studied and adapted to measure the effectiveness of changes in poultry processing and inspection system changes now being proposed and implemented. Certainly, an adequate and affordable supply of high quality and safe poultry and eggs will contribute to the health of the nation in the year 2000 and beyond. Two other reports give us a wealth of information on the health of the nation related to the consumption of poultry and eggs. Foegeding and Roberts' CAST Reports (Foegeding and Roberts, 1994; Roberts et al, 1995) are probably the most extensive review of the literature on the risks and consequences of food borne pathogens. Although they agree that the estimates of the cases of microbial foodborne disease are not known with accuracy, current estimates range from 6.5 to 33 million annually and that deaths may range from 525 to 9,000. However, last year, 17,274 Americans were killed by drunk drivers, over twice as many as the higher estimate for food-related deaths. Food deaths account for less than 1% of the 2 million total annual deaths in the U.S. It is estimated that the cost of these foodborne illnesses are $5 to 6 billion per year. As most foodborne diseases do not require reporting, the actual numbers may be much higher, particularly in the elderly, infants, and the immunocomprised. Foegeding and Roberts (1994) summarized other reports and separated the cause of the illness into mishandling in food,, service establishments, homes, and food processing establishments. Although the estimates vary widely with different etiologic agents, in the case of Salmonella, 95% of the cases were from
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U.S. The same principles that assure quality, assure safety. Safety, like quality, must be manufactured in, it cannot be inspected in! I hope that you have noticed that up to now, I have not made statements that "our food is safe" or that "Our poultry and poultry products are the safest in the world!" I have done this intentionally because I wanted to give you a flavor of the science supporting the food safety efforts and regulatory system modifications that will eventually improve on the safety of poultry and poultry products. Traditionally, many of us have measured or at least, estimated, the safety of a food by the amount of a biological, chemical, or physical hazard that might be present. Although it is, at best an inexact science, we have been able to estimate the risk from a particular chemical or physical hazard. But in the case of biological hazards, for which we do not even know the infectious dose, nor what happens if the product is temperature abused during the trip to the table, determination of the risk is practically impossible! Microbiological standards, or performance standards are therefore useless! From a global perspective our concerns should be with the health of the people of the nation. All factors affecting the health of the people should be considered. Progress toward a healthier population can be measured, and then we can see if the modifications made in manufacturing and yes, even inspection, have benefited, and we can begin to arrive at a costbenefit ratio. Longer time intervals will be involved, but we will be looking at real data and real benefits, as contrasted, for example, the reduction of Salmonella on poultry, i.e., from 20% positive carcasses to 15% positive carcasses. In the U.S., we have made an important start with the publication of Healthy People 2000: National Health Promotion and Disease Prevention Objectives published in 1990 and the follow-up publication of Midcourse Review and 1995 Revisions (Lee, 1995). Healthy People 2000 provides a vision for achieving improved health for all Americans. Through a national process, people from across the country helped define and are pursuing a prevention agenda for the nation. These reports emphasize that prevention is the foundation for health. A CDC 1994 assessment estimated that nearly 47% of premature deaths among Americans could have been avoided by changes in individual behaviors and another 17% by reducing environmental risks. Of the 2.1 million deaths in the U.S. in 1992, onethird were attributable to heart disease and one-fourth to cancers. The report listed a number of risk reduction strategies of interest:
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1,912 cfu/mL
Coliforms Escherichia coli Clostridia fringens Staphylococcus aureus Listeria monocytogenes Campylobacter jejuni/coli Salmonella
60 32 7.2 13 0.13 MPNVmL 21 0.16
!MPN = most probable number.
and analyzed for bacterial levels. Researchers found C. jejuni/coli on 88% of the carcasses, Staphylococcus aureus on 64%, Clostridium perfringens on 43%, Salmonella on 20% and L. monocytogenes on 15%. No E. coli 0157:H7 were found. In the broiler carcasses that tested positive, the geometric mean of the organisms in the carcass rinse water are shown in Table 1. Although all of these baseline studies support each other and all the counts are very low, they say nothing about the health of the population or the amount or cost of foodborne illness, which is the real reason for all the regulations and research in the first place. We must begin to seriously look at the effect of our research, our regulations, our quality assurance programs, and our educational activities on the health of the nation and the reduction of foodborne illness. How do we measure improvements in the public health that may be the result of these activities? How do we establish the appropriate allocation of limited resources? How can we set the priorities for funding research, regulation, or education, if we can't measure the benefits? We must address these questions. We loudly proclaim that all policy and regulatory decisions must be based on sound science, but what kind of science? Now we find ourselves dealing with segments of the population who are making decisions that really effect us—consumers, who buy and eat our products, and policy makers and politicians, who fund our research and regulate our processes. These are people who do not understand "parts per million" of "colony-forming units per carcass"; these are people who do not look at risk the same way as scientists. How do we deal with these people? We must look beyond the science we know and practice so well. We must look at least one of the social sciences, political science! One of the basic tenants of political science is compromise. How do scientists deal with compromise? First, not very well, but we must learn to do so. We must go into the "compromise negotiation" with all of the sound facts we can, the sound baseline, if you will. Then we must understand as much as we can about our opponents' position and know as much as possible about their sometimes "hidden" agenda. HACCP, risk assessment, the "mega-reg", and pathogen reduction have been filled with compromise and as finally issued, this
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mishandling in food service establishments and the home. Certainly, microbial performance standards in the plant or inspection system would have very little meaning. They concluded that increased efficiency in providing safer food results from 1) better risk assessment databases being developed and 2) increased use of a systems approach, such as HACCP, to identify where pathogens or their toxins come into the food chain (or where mishandling permits their growth) and to reduce the likelihood of foodborne illness. Buzby and Roberts (Buzby, 1995) claim that the range of costs of $5.6 to $9.4 billion are seriously underestimated, and that estimates may be larger in the next decade with improved reporting and estimation procedures. This finding demonstrates the difficulty of measuring progress from a baseline that is so poorly defined. If the baselines for health, and for foodborne illness are poorly defined, are those for microbial performance any better? Certainly not: as a point of fact, for food as it is consumed, we have no information at all. If we go back in the system to where we have any information, we must go back to the products as they are packaged in the processing plants, to that part of the system where the new proposed regulations would impose microbiological performance standards. What do we know about these baselines? One of the first comprehensive, industry-wide efforts to establish not only a base line, but the effect of some system modifications was reported by Waldroup and her co-workers (Waldroup et al, 1992). Approximately 1,000 samples of commercial broilers in five plants were analyzed for aerobic plate counts (less than 8,000 cfu/ mL of carcass rinse), coliform (340 cfu/mL carcass rinse), E. coli (120 cfu/mL carcass rinse), Salmonella (less than 2 organisms per carcass), Listeria monocytogenes (less than 5 organisms per carcass), and Campylobacter jejuni/coli (3,160 per carcass). The average percentage positive carcasses for Salmonella was 40%. Although there were differences between plants and between the baseline and the modification samples, this study demonstrated that the levels of spoilage and pathogenic organisms were very low, and without abuse or possible consumption by an immuncomprised individual, would not cause foodborne illness. A series of studies were conducted by USDA-FSIS scientists in the FSIS Puerto Rico Bacterial Control Project in the 1980s to determine the effect of some processing modifications on the microbial levels of broiler carcasses (James et al, 1992a; James et al, 1992b; James et al, 1992c; James et al, 1993). The results for the aerobic plate counts, coliforms, and E. coli were similar to those found by Waldroup, confirming that there are low levels of these organisms. Postchill carcasses ranged from 50 to 75% positive for Salmonella. The USDA-FSIS has just recently completed a baseline survey (FSIS-USDA, 1996) in which 1297 broiler chicken carcasses were collected from federally inspected plants
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So far, I have addressed research inputs to food safety, regulation of food safety, and a brief comment on the politics of food safety and now I would like to comment on education and food safety. The CAST Report (Foegeding and Roberts, 1994) documented that much (we could argue about the exact amount) of foodborne illness is due to mishandling during preparation and consumption. Indeed, this has been acknowledged by the wide-spread use of the slogan, "From Farm to Table" in USDA documents and press releases. With
about 45% of food consumed away from the home (Manchester and Clausen, 1995), a large portion of that which is eaten is in so called "fast food" outlets. We are reminded that the catalyst for the most recent demands for inspection changes has resulted from children, who died after eating undercooked hamburgers. What should be our first priority? Perhaps we can get our answer by the response of the company, Jack in the Box, who had the most to lose from this unfortunate incident. Immediately following the outbreak, the company boldly moved to cooperate with public health departments and strengthened their quality assurance, product safety and research and development departments. Perhaps, of most long-range importance was the partnership formed with the National Restaurant Association in June 1993, less than 6 mo after the incident, to train all management personnel in ServSafe, a NRA food safety training program for restaurant workers. In September 1994, Jack in the Box became the first large operator to have all restaurant managers certified with the NRA ServSafe program. Many other fast food franchises have initiated similar programs, many working with the National Restaurant Association, which has trained over 500,000 managers in techniques to further train their employees. With very rapid turnover of employees in these eating establishments, training is an on-going necessity. The USDA has developed an extensive group of training aids for instructors and for self use. These are easily available from FSIS-USDA through their Meat and Poultry Hotline, 1-800-535-4555 and their Internet H o m e Page h t t p / / w w w . u s d a . g o v / a g e n c y / f s i s / homepage.htm. In 1993, the Food and Drug Administration published a revision of the 1976 Food Code containing detailed and sometimes controversial food handling procedures. After some modifications, the National Restaurant Association has supported the uniform code. This code is a valuable educational resource. The land grant colleges should play an important role in this educational effort. The extensive experience in food safety research, the large network of home economists and extension specialists forms not only the largest, but the most highly educated groups qualified to train food service workers and consumers in good food handling practices. Almost every city, county, or state has some kind of a hotel, restaurant, or tourist agency, most of them at least partially financed by a tax on hotel rooms or food and beverages. Who better to pay for training food handlers than those who will benefit the most. Although I know other states have similar programs, Dr. John Marcy, at the University of Arkansas, has developed a very successful "Train the Trainer" program in cooperation with the Arkansas Hotel and Restaurant Association. This program has now been expanded to include child day care centers, another potential for foodborne illness. All involved in food production, both plant and
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regulation is still a compromise! If we are to learn how to compromise we must learn how to assess and manage risk. Risk scientists and risk managers are often coming from a different background. As risk scientists we must learn that "risk trade-offs" can be accepted. A good example of this is the recent negotiation with the Russians on banning American broilers. From the beginning, it was recognized that the ban was based more on internal Russian politics than on unsanitary American broiler plants. Mr. Yeltsin was running for reelection and his rival Communists wanted to stimulate domestic industry and agricultural production and part of their plan was a significant reduction in imports. Dr. Amy Waldroup, of University of Arkansas, has been to Russia several times and visited Russian poultry plants. She reported (Waldroup, personal communication) "I have toured both chicken and turkey processing plants throughout the former Soviet Union. Some of their equipment is very modern; however, sanitation is truly at a minimum. Temperature control does not appear to be very important to Russian processors. In the former Soviet Union, the priority is feeding people—food safety does not appear to be a concern. That is why I was so surprised by the recent problems related to our exports to Russia." When the Russians threatened to ban all exports to U.S. broilers early this year, the risk of an economic disaster was very high, Russia had become the largest market for U.S. poultry exports, with sales of more than $700 million in 1995, almost all of which is the dark meat, usually in surplus in the U.S. An arrangement was made for Russian veterinarians to inspect all the plants shipping broilers to Russia, at a cost to the plant of at least $2,000 per plant. In further negotiations, it was agreed that a Salmonella analysis would be conducted on a 25-g sample of muscle, not skin, per consignment, which could have been a shipload. And furthermore if this sample was positive, a second sample would be taken, and if negative, the consignment cleared. All of us know, based on the USDA baseline data and industry experience, that the chances of rejection were very small. This was certainly not good science but a necessary compromise to lift the poultry ban. In a related event, the International Monetary Fund offered Russia $10.2 billion in new loans, on conditions designed to free international trade, and on the next day the Russians dropped the ban. There is no doubt that politics were an important consideration in Russian poultry import policy.
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a n i m a l , food processors, food distributors, retailers, a n d institution m a n a g e r s , food service o p e r a t o r s , a n d cons u m e r s m u s t p u t e d u c a t i o n at a v e r y h i g h priority. G o o d research only in p r i n t e d journals r e m a i n s just g o o d research. G o o d regulations r e m a i n i n g only in code b o o k s are just g o o d regulations. But, g o o d politics get politicians re-elected. G o o d food safety e d u c a t i o n m e a n s less illness, d e a t h , a n d h u m a n suffering.
REFERENCES
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Acker, D., 1993. An Overview of Federal Food Safety Research. Report by the Committee on Food, Agricultural, and Forestry of the Federal Coordinating Council for Science, Engineering, and Technology, Washington, DC. Bowers, P., 1996. A buffet of inspection changes. Poultry marketing and technology, February/March:22-24. Buchanan, R. L., 1990. HACCP: A re-emerging approach to food safety. Trends Food Sci. Technol. Nov:104-106. Buzby, J. C , and T. Roberts, 1995. ERS Estimates U. S. foodborne disease costs. Food Rev. 18:37-42. Clinton, W. J., 1996. Meeting the Challenge. A Research Agenda for America's Health, Safety and Food. Executive Office of the President/Office of Science and Technology Policy. Washington, DC. Committee, 1992. Hazard Analysis and Critical Control Point System. The National Advisory Committee on Microbiological Criteria for Foods. Int. J. Food Microbiol. 16:1-23. Disser, L. A., 1996. IFT Says End-Product Testing won't Assure Lower levels of Pathogens, Institute of Food Technologists, Chicago, IL. Evenson, R. E., 1989. Ag research—A wise public investment. South Carolina Agric. 1:3. Foegeding, P. M., and T. Roberts, 1994. Foodborne Pathogens: Risks and Consequence. Council for Agricultural Science and Technology. CAST Force Report #122. Ames, IA. Food and Nutrition Board, National Research Council, 1985. Meat and Poultry Inspection. The Scientific Basis of the Nation's Program. National Academy Press, Washington, DC.
Food and Nutrition Board, National Research Council, 1987. Poultry Inspection. The Basis for a Risk-Assessment Approach. National Academy Press, Washington, DC. FSIS-USDA. 1995. 9 CFR Parts 308, 310, 318, 320, 325, 326, 327, and 381. Pathogen Reduction; Hazard Analysis and Critical Control Point (HACCP) Systems; Proposed Rule. Fed. Reg. 60:6773-6889. FSIS-USDA. 1996. Nationwide Broiler Chicken Microbiological Baseline Data Collection Program. Washington, DC. James, W. O., R. L. Brewer, J. C. Prucha, W. O. Williams, and D. R. Parhamm, 1992a. Effects of chlorination of chill water on the bacteriologic profile of raw chicken carcasses and giblets. JAVMA 200:60-63. James, W. O., and W. O. Williams, J. C. Prucha, R. Johnson, and W. Johnson, 1992b. Profile of selected bacterial counts and Salmonella prevalence on raw poultry in a poultry slaughter establishment. JAVMA 200:57-59. James, W. O. and J. C. Prucha, R. L. Brewer, W. O. Williams, W. A. Christensen, A. M. Thaler, and A. T. Hogue, 1992c. Effects of countercurrent scalding and postscald spray on the bacteriologic profile of raw chicken carcasses. JAVMA 201:705-708. Lee, P. R., 1995. Healthy People 2000: Midcourse Review and 1995 Revisions. U. S. Department of Health and Human Services, Public Health Service. Washington, DC. Manchester, A., and A. Clausen, 1995. 1994 Spending for food away from home outpaces food at home. Food Rev. 18: 12-15. Roberts, T., H. Jensen, and L. Unnevehr, 1995. Tracking foodborne pathogens from farm to table: Data needed to evaluate control options. USDA, Economic Research Service. Misc. Publication 1532. Washington, DC. Waldroup, A. L., B. M. Rathgeber, R. Forsythe, and L. Smoot, 1992. Effects of six modifications on the incidence and levels of spoilage and pathogenic organisms on commercially processed postchill broilers. J. Appl. Poult. Res. 1: 226-234. Williams, J. O., J. C. Prucha, and R. L. Brewer, 1993. Costeffective techniques to control human enteropathogens on fresh poultry. Poultry Sci. 72:1174-1176.
(Key words: food safety, inspection, education, research, regulation) 1996 Poultry Science 75:1448-1454
I was honored when the Program Committee asked me to present the World Poultry Science Association (WPSA) lecture, first because of my long association with WPSA, but more importantly because it presented an opportunity to take a serious look at the current status of the safety of our food supply, particularly, the safety of poultry and eggs. When I chose the topic "Food Safety: A Global Perspective", I was thinking beyond an "International Perspective" because the invitation and may choice of the topic came well before the Bovine Spongiform Encephalopathy (BSE) episode in the United Kingdom and its possible relationship with Creutzfeldt-Jakob disease (CJD) in humans, the Russian criticism of the U.S. poultry inspection system, and the subsequent proposed ban on poultry exports. Because these activities are part of the politics of food safety, I will have some further comments later. I was actually thinking of "global" in a more "universal" sense. "Global," means the entire food system, as in the current catchy phrase "farm to table", includes farm production, processing, marketing, and distribution, restaurant and institutional food service, and home preparation. And "global" encompasses the infrastructure of the system, which includes food research and product development, regulation, inspection and quality assurance, risk assessment, legislative or political input, education and extension, the media, and last, but certainly not least, consumer groups. Most particularly,
Received for publication July 11, 1996. Accepted for publication August 2, 1996.
"global" includes the health and well-being of the American people. In the next few minutes, I will review the status of the food safety agenda of some of these entities (agencies), and how they will contribute not just to safe food, but to a healthier population. Because many of this audience are researchers, let's look first at research. A government Food Safety Research Workgroup report An Overview of Federal Food Safety Research, Including the Research Needs for the Future from the Committee on Food, Agricultural, and Forestry of the Federal Coordinating Council for Science, Engineering, and Technology was published in January 1993 (Acker, 1993). In her transmittal letter Chairperson, Dr. Catherine W. Carnevale stated "The Food Safety Research Workgroup members recognized that the character of the food supply is changing. New sources of food, natural and synthetic, as well as increasing imports, present food safety regulators with new challenges and concerns. Furthermore, increased trade in food worldwide has led many countries to seek assurance that products meet their country's safety requirements. Food safety concerns have become global, necessitating that food safety research be approached from a global perspective." This report documents that 21 federal agencies spend about 200 million dollars per year on food safety research under approximately 50 laws that directly or indirectly authorize such research. The departments carrying out food research included in the report were Agriculture, Health and Human Services, National Institutes of Health, Commerce, State, Defense and the Environmental Protection Agency (EPA). These departments, which spent the $200 million plus for food safety research, also spent over $12 billion for what they called
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ABSTRACT The health of the population of the U.S. is affected by many factors, not the least of which is its food supply. A major source of high quality animal protein comes from poultry, eggs, and meat. The major effect of personal habits and the environment, diet, tobacco, alcohol, are considered, along with the microbiological effect on foodborne illness and health. The inspection system for meat and poultry is reviewed, in light of the publication of significant revisions being
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Although admittedly, it is a very rough estimate, based on the federal investment of $200 million, and state and industry matching data based on the Food Safety Consortium experience, we can estimate that at least $400 million in research and technology development is spent annually in the U.S. This amount is a rather small part, actually less than 0.1%, of the $647 billion we spent for food in the U.S. in 1994, of which over 45% was spent away from home (Manchester and Clausen, 1995). This expenditure on research really does not seem like a major global effort! We are able to determine a cost:benefit ratio of many agriculture research activities. For example, Dr. Robert Evenson, Professor of Economics at Yale, reported that agriculture research in South Carolina returned $12 for each dollar invested (Evenson, 1989). In a personal communication with Dr. Evenson, he thought that realistically for the country the return might be nearer $4 to 5. The effect of research in reducing costs can be documented in many cases. For example, if, through genetic research, we could increase broiler breast meat by 1%, and if we applied that to only 20% of the Arkansas broilers, their value would be increased by over $10 million. Unfortunately, we have been unable, to develop similar hard data for the return on investment in food safety research. President Clinton, in 1993 (Clinton, 1996), established the cabinet-level, National Science and Technology Council (NSTC) to coordinate science, space, and technology policies across the federal government. Recognizing that the health and well-being of Americans was central to the President's strategy, NSTC and the Office of Science and Technology Policy of the Executive Office of the President convened a forum at the National
Academy of Sciences in late 1994 that addressed questions fundamental to America's health and wellbeing. The policy document resulting from this forum, Meeting the Challenge—A Research Agenda for America's Health, Safety and Food, was published in February, 1996 and identified four common themes cutting across all priority issues. These were: 1) Health, Safety, and Food Research, 2) Prevention, 3) Communication, and 4) Education. In the document, Phil R. Lee, M.D., Assistant Secretary for Health, Health and Human Services stated "From a health standpoint, there is no question that the money invested in science over the past five decades has been very well spent. Americans are living longer, better and since the turn of the century, one should note that the average life expectancy has increased from 47 to 75 yr." Poultry scientists have contributed significantly to this research and would do well, along with their administrators and funding sources, to use this report to justify their requests for funding. Research expenditures are not the only, and actually probably are only a minor part of the cost of ensuring that safe food is supplied to consumers. The major public regulatory costs of food safety programs are in the Food and Drug Administration (FDA), which is responsible for all food other than meat and poultry, and the Food Safety Inspection Service (FSIS) of the Department of Agriculture, which is responsible for meat and poultry. The FDA projected Fiscal year (FY) 93 budget was just under $800 million. The FSIS budget for that same year was just under $500 million. These two regulatory costs of $1.3 billion, are still less than 0.2% of the value of the food at the consumer level. Also included in the FSIS budget is the cost of almost 8,000 inspectors in over 6,200 federally inspected meat and poultry plants, who at best can reduce visual defects, which result in partial or whole bird condemnation. Condemnation rates are consistently less than 3 birds out of every 100. It is hard to imagine looking at so many birds! This organoleptic inspection system is in serious need of overhaul and has been the subject of critical review by USDA, industry, and consumer groups since early 1993, when there was an outbreak of Escherichia coli 0157:H7 in children eating undercooked hamburgers on the west coast. It should be pointed out that this review process did not start with Mike Espy or Dan Glickman, or Bill Clinton. This review started in late 1983, when FSIS asked the Food and Nutrition Board (FNB) of the National Research Council to evaluate the scientific basis of the current system for inspecting meat and poultry (Food and Nutrition Board, 1985). This Committee Report issued in 1985 recommended that FSIS intensify its current efforts to control and eliminate microorganism contamination that causes disease in humans. These efforts were to include evaluation of rapid diagnostic procedures for detection, and education of the general public, health care personnel, educators, and extension service workers in the safe handling of meat and
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"other" research, committing less than 2% of federal research dollars to research on the safety of our food supply. How global is federal food safety research? Developing an estimate of financial resources from state and private funding is much more difficult. In the three-state Food Safety Consortium (Iowa State, Kansas, and Arkansas) our goal was to exceed a match of $1 for every $1 of federal funding. The Consortium consistently exceeds that goal. Data on research support from private industry, other than that tunneled through trade o r g a n i z a t i o n s is g e n e r a l l y n o t available. The Southeastern Poultry and Egg Association invests over $1 million/yr, and currently has 85 projects being funded, an investment in research of almost $3 million. Although not all of this investment relates to egg and poultry product safety, a significant effort of public and private scientists is devoted to improving the safety of our products. Other trade associations, including the National Turkey Federation, the National Broiler Council, the Pacific Egg and Poultry Association, the Midwest Poultry Association, the United Egg Producers, and many state and regional associations contribute significantly to the research effort through continuing contact with both federal and state funding agencies to emphasize research needs.
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poultry. The Committee also recommended "that means be found for FSIS to coordinate the control and monitoring of hazardous agents during production, where those agents enter the food supply." Sounds like "farm to table". The Committee also recommended "that the precepts of risk assessment be included in any modifications of the inspection system. The Committee considered, at FSIS's specific request, to explore whether bird-by-bird inspection might be modified, but it recommended that before the traditional inspection be changed, a comparative risk analysis of any new inspection technology and the traditional system be conducted. This analysis has never been done!
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Immediately upon the issuance of that report, the FSIS Administrator requested that the National Research Council conduct a follow-up study, specifically for poultry (Food and Nutrition Board, 1987). "The committee concluded, in agreement with the earlier Committee...that FSIS should consider using risk-assessment techniques to manage and control poultry associated hazards." The Committee developed several risk-models in which flow charts with potential hazardous activities were identified, the magnitude of the health risk was accessed and the critical factors were identified that might influence the magnitude of the risk. From this beginning, in 1987 the hazard analysis and critical control point (HACCP) approach (Buchanan, 1990), earlier developed by a team at the Pillsbury Company as a means of assuring the safety of foods produced for the U.S. space program, was introduced to FSIS. The National Advisory Committee on Microbiological Criteria for Food (Committee, 1992), a group of distinguished public and private scientists, established that HACCP is a systematic approach to food safety consisting of seven principles. Briefly these seven principles are: 1) conduct a hazard analysis, 2) identify Critical Control Points (CCP), 3) establish CCP limits, 4) establish monitoring requirements, 5) establish corrective actions, 6) develop record-keeping procedures, and 7) develop procedures for verification that the system is working. Although the HACCP system has been widely discussed, these principles have never changed. Following innumerable workshops, public hearings, seminars, congressional hearings, conferences, and "false starts", the "war on pathogens" was joined when Secretary Mike Espy in late 1993 commissioned the USDA Pathogen Reduction Task Force (PRTF) "to provide leadership, coordination and oversight of the Department's programs to ensure a safe and wholesome meat and poultry food supply." On February 3, 1995, FSIS (FSIS, 1995) published the long-awaited proposed rule to modify, add to, or eliminate portions of the regulations for the inspection of meat and poultry. According to Michael Taylor (USDA News Release, February 1,1995), acting under secretary for Food Safety and administrator of FSIS: "These proposals mark a fundamental shift. They are targeted to improve the safety of meat and poultry products directly by
addressing the pathogenic microorganisms that cause most food-related illnesses and by increasing our ability to ensure that all meat and poultry companies follow sound food safety procedures." The first part of this statement was directed toward microbiological standards and the second part to HACCP. One of the most controversial parts of the proposed rule has been the requirement for Salmonella testing. Time and space do not permit a review of the thousands of pages of comments from every trade association, many consumer advocate groups, the inspectors union (National Joint Council of Food Inspection Locals), the media, and academic science professionals. To believe that partisan politics did not play an important role in these discussions would be naive! The Institute of Food Technologists (Disser, 1996) submitted comments that included "There is no question that we need to move to a science-based system for inspecting meat and poultry. That doesn't mean, however, that randomly testing raw meat and poultry for pathogens is the best way to reduce bacterial contamination." Michael Taylor stated early this year in Atlanta "FSIS hopes to publish a final rule early this year" (Bowers, 1996). As these remarks were being prepared in early June, 1996 the HACCP final rule had gone to the Office of Management and Budget. On July 6, 1996, President Clinton announced that the rule had been finalized and would be published in the Federal Register within a few days. An advance copy was distributed to trade associations in Washington on Monday, July 8, 1996. Microbiological performance standards are included in the rule. H. Russell Cross, the Executive Director of the International Meat and Poultry HACCP Alliance commented (Bowers, 1995) that no one has the data to set any level of bacterial standard "The reason is that we don't have the infectious dose data to do any kind of a risk analysis, so any number we pick will be arbitrary." Cross says that USDA should conduct continual baseline surveys of key pathogens to provide a yardstick for industry to determine if it is making progress over time. It would appear that others in the Small Business Administration (SBA) and the Office of Management of the Budget (OMB) agreed with Dr. Cross, and attempted to change the microbiological testing requirements, thus delaying the issuance of the final rule, but without success! The food industry, including most poultry companies in the past decade have moved from a concept of Quality Control, in which a battery of inspectors looked for defects and then rejected those products failing to meet standards all through the processing system, to Quality Assurance, in which Good Manufacturing Practices, many including the HACCP principles, are designed to manufacture products without defects and have significantly reduced or eliminated the need for inspectors. Make it right the first time! This is the religion of Dr. Edward Deming, who turned manufacturing systems around, first in Japan, and then in the
WORLD'S POULTRY SCIENCE ASSOCIATION INVITED LECTURE
Elimination of tobacco use would prevent over 400,000 deaths; and diet and exercise would prevent 300,000 deaths. Since the 1970's: stroke death rates have declined by 58%, coronary heart disease has dropped by 49%, and tobacco use among adults has declined form 34% to 25%.
The report goes on to estimate the costs of these serious illnesses, chronic disabilities, and premature
deaths, i.e., heart disease and stroke cost $135 billion annually, alcohol abuse costs $98.6 billion, and tobacco abuse costs $65 billion. Three major measurable goals were identified. Goal 1. Increase the span of healthy life. That portion of ones life with few limitations of major life activities, in 1990, 64 yr of a total 75.4 yr life expectancy, i.e., 11.4 yr of unhealthy or limited life activities. Goal 2. Reduce health disparities among Americans. Blacks had healthy life expectancy of 69.1 total yr, compared to whites, 76.1 yr, and a healthy life of 56 yr. Goal 3. Achieve access to preventative services for all Americans. Seventy-seven percent of people under 65 yr had private insurance in 1986, only 71.9% had it in 1992, a very serious decline. Although food and drug safety were not included as a separate category in 1990, it was discussed in the 1995 update. The rate of Salmonella infections was targeted for 16 per 100,000 for 2000, but in 38 states, the rate was below the target, actually exceeding the goal by 200%. Salmonella enteritidis outbreaks were reduced from 77 in 1989 to 63 in 1993, demonstrating the effectiveness of the S. enteritidis Prevention Programs in Pennsylvania and elsewhere. The 1995 report update report should be carefully studied and adapted to measure the effectiveness of changes in poultry processing and inspection system changes now being proposed and implemented. Certainly, an adequate and affordable supply of high quality and safe poultry and eggs will contribute to the health of the nation in the year 2000 and beyond. Two other reports give us a wealth of information on the health of the nation related to the consumption of poultry and eggs. Foegeding and Roberts' CAST Reports (Foegeding and Roberts, 1994; Roberts et al, 1995) are probably the most extensive review of the literature on the risks and consequences of food borne pathogens. Although they agree that the estimates of the cases of microbial foodborne disease are not known with accuracy, current estimates range from 6.5 to 33 million annually and that deaths may range from 525 to 9,000. However, last year, 17,274 Americans were killed by drunk drivers, over twice as many as the higher estimate for food-related deaths. Food deaths account for less than 1% of the 2 million total annual deaths in the U.S. It is estimated that the cost of these foodborne illnesses are $5 to 6 billion per year. As most foodborne diseases do not require reporting, the actual numbers may be much higher, particularly in the elderly, infants, and the immunocomprised. Foegeding and Roberts (1994) summarized other reports and separated the cause of the illness into mishandling in food,, service establishments, homes, and food processing establishments. Although the estimates vary widely with different etiologic agents, in the case of Salmonella, 95% of the cases were from
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U.S. The same principles that assure quality, assure safety. Safety, like quality, must be manufactured in, it cannot be inspected in! I hope that you have noticed that up to now, I have not made statements that "our food is safe" or that "Our poultry and poultry products are the safest in the world!" I have done this intentionally because I wanted to give you a flavor of the science supporting the food safety efforts and regulatory system modifications that will eventually improve on the safety of poultry and poultry products. Traditionally, many of us have measured or at least, estimated, the safety of a food by the amount of a biological, chemical, or physical hazard that might be present. Although it is, at best an inexact science, we have been able to estimate the risk from a particular chemical or physical hazard. But in the case of biological hazards, for which we do not even know the infectious dose, nor what happens if the product is temperature abused during the trip to the table, determination of the risk is practically impossible! Microbiological standards, or performance standards are therefore useless! From a global perspective our concerns should be with the health of the people of the nation. All factors affecting the health of the people should be considered. Progress toward a healthier population can be measured, and then we can see if the modifications made in manufacturing and yes, even inspection, have benefited, and we can begin to arrive at a costbenefit ratio. Longer time intervals will be involved, but we will be looking at real data and real benefits, as contrasted, for example, the reduction of Salmonella on poultry, i.e., from 20% positive carcasses to 15% positive carcasses. In the U.S., we have made an important start with the publication of Healthy People 2000: National Health Promotion and Disease Prevention Objectives published in 1990 and the follow-up publication of Midcourse Review and 1995 Revisions (Lee, 1995). Healthy People 2000 provides a vision for achieving improved health for all Americans. Through a national process, people from across the country helped define and are pursuing a prevention agenda for the nation. These reports emphasize that prevention is the foundation for health. A CDC 1994 assessment estimated that nearly 47% of premature deaths among Americans could have been avoided by changes in individual behaviors and another 17% by reducing environmental risks. Of the 2.1 million deaths in the U.S. in 1992, onethird were attributable to heart disease and one-fourth to cancers. The report listed a number of risk reduction strategies of interest:
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1,912 cfu/mL
Coliforms Escherichia coli Clostridia fringens Staphylococcus aureus Listeria monocytogenes Campylobacter jejuni/coli Salmonella
60 32 7.2 13 0.13 MPNVmL 21 0.16
!MPN = most probable number.
and analyzed for bacterial levels. Researchers found C. jejuni/coli on 88% of the carcasses, Staphylococcus aureus on 64%, Clostridium perfringens on 43%, Salmonella on 20% and L. monocytogenes on 15%. No E. coli 0157:H7 were found. In the broiler carcasses that tested positive, the geometric mean of the organisms in the carcass rinse water are shown in Table 1. Although all of these baseline studies support each other and all the counts are very low, they say nothing about the health of the population or the amount or cost of foodborne illness, which is the real reason for all the regulations and research in the first place. We must begin to seriously look at the effect of our research, our regulations, our quality assurance programs, and our educational activities on the health of the nation and the reduction of foodborne illness. How do we measure improvements in the public health that may be the result of these activities? How do we establish the appropriate allocation of limited resources? How can we set the priorities for funding research, regulation, or education, if we can't measure the benefits? We must address these questions. We loudly proclaim that all policy and regulatory decisions must be based on sound science, but what kind of science? Now we find ourselves dealing with segments of the population who are making decisions that really effect us—consumers, who buy and eat our products, and policy makers and politicians, who fund our research and regulate our processes. These are people who do not understand "parts per million" of "colony-forming units per carcass"; these are people who do not look at risk the same way as scientists. How do we deal with these people? We must look beyond the science we know and practice so well. We must look at least one of the social sciences, political science! One of the basic tenants of political science is compromise. How do scientists deal with compromise? First, not very well, but we must learn to do so. We must go into the "compromise negotiation" with all of the sound facts we can, the sound baseline, if you will. Then we must understand as much as we can about our opponents' position and know as much as possible about their sometimes "hidden" agenda. HACCP, risk assessment, the "mega-reg", and pathogen reduction have been filled with compromise and as finally issued, this
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mishandling in food service establishments and the home. Certainly, microbial performance standards in the plant or inspection system would have very little meaning. They concluded that increased efficiency in providing safer food results from 1) better risk assessment databases being developed and 2) increased use of a systems approach, such as HACCP, to identify where pathogens or their toxins come into the food chain (or where mishandling permits their growth) and to reduce the likelihood of foodborne illness. Buzby and Roberts (Buzby, 1995) claim that the range of costs of $5.6 to $9.4 billion are seriously underestimated, and that estimates may be larger in the next decade with improved reporting and estimation procedures. This finding demonstrates the difficulty of measuring progress from a baseline that is so poorly defined. If the baselines for health, and for foodborne illness are poorly defined, are those for microbial performance any better? Certainly not: as a point of fact, for food as it is consumed, we have no information at all. If we go back in the system to where we have any information, we must go back to the products as they are packaged in the processing plants, to that part of the system where the new proposed regulations would impose microbiological performance standards. What do we know about these baselines? One of the first comprehensive, industry-wide efforts to establish not only a base line, but the effect of some system modifications was reported by Waldroup and her co-workers (Waldroup et al, 1992). Approximately 1,000 samples of commercial broilers in five plants were analyzed for aerobic plate counts (less than 8,000 cfu/ mL of carcass rinse), coliform (340 cfu/mL carcass rinse), E. coli (120 cfu/mL carcass rinse), Salmonella (less than 2 organisms per carcass), Listeria monocytogenes (less than 5 organisms per carcass), and Campylobacter jejuni/coli (3,160 per carcass). The average percentage positive carcasses for Salmonella was 40%. Although there were differences between plants and between the baseline and the modification samples, this study demonstrated that the levels of spoilage and pathogenic organisms were very low, and without abuse or possible consumption by an immuncomprised individual, would not cause foodborne illness. A series of studies were conducted by USDA-FSIS scientists in the FSIS Puerto Rico Bacterial Control Project in the 1980s to determine the effect of some processing modifications on the microbial levels of broiler carcasses (James et al, 1992a; James et al, 1992b; James et al, 1992c; James et al, 1993). The results for the aerobic plate counts, coliforms, and E. coli were similar to those found by Waldroup, confirming that there are low levels of these organisms. Postchill carcasses ranged from 50 to 75% positive for Salmonella. The USDA-FSIS has just recently completed a baseline survey (FSIS-USDA, 1996) in which 1297 broiler chicken carcasses were collected from federally inspected plants
WORLD'S POULTRY SCIENCE ASSOCIATION INVITED LECTURE
So far, I have addressed research inputs to food safety, regulation of food safety, and a brief comment on the politics of food safety and now I would like to comment on education and food safety. The CAST Report (Foegeding and Roberts, 1994) documented that much (we could argue about the exact amount) of foodborne illness is due to mishandling during preparation and consumption. Indeed, this has been acknowledged by the wide-spread use of the slogan, "From Farm to Table" in USDA documents and press releases. With
about 45% of food consumed away from the home (Manchester and Clausen, 1995), a large portion of that which is eaten is in so called "fast food" outlets. We are reminded that the catalyst for the most recent demands for inspection changes has resulted from children, who died after eating undercooked hamburgers. What should be our first priority? Perhaps we can get our answer by the response of the company, Jack in the Box, who had the most to lose from this unfortunate incident. Immediately following the outbreak, the company boldly moved to cooperate with public health departments and strengthened their quality assurance, product safety and research and development departments. Perhaps, of most long-range importance was the partnership formed with the National Restaurant Association in June 1993, less than 6 mo after the incident, to train all management personnel in ServSafe, a NRA food safety training program for restaurant workers. In September 1994, Jack in the Box became the first large operator to have all restaurant managers certified with the NRA ServSafe program. Many other fast food franchises have initiated similar programs, many working with the National Restaurant Association, which has trained over 500,000 managers in techniques to further train their employees. With very rapid turnover of employees in these eating establishments, training is an on-going necessity. The USDA has developed an extensive group of training aids for instructors and for self use. These are easily available from FSIS-USDA through their Meat and Poultry Hotline, 1-800-535-4555 and their Internet H o m e Page h t t p / / w w w . u s d a . g o v / a g e n c y / f s i s / homepage.htm. In 1993, the Food and Drug Administration published a revision of the 1976 Food Code containing detailed and sometimes controversial food handling procedures. After some modifications, the National Restaurant Association has supported the uniform code. This code is a valuable educational resource. The land grant colleges should play an important role in this educational effort. The extensive experience in food safety research, the large network of home economists and extension specialists forms not only the largest, but the most highly educated groups qualified to train food service workers and consumers in good food handling practices. Almost every city, county, or state has some kind of a hotel, restaurant, or tourist agency, most of them at least partially financed by a tax on hotel rooms or food and beverages. Who better to pay for training food handlers than those who will benefit the most. Although I know other states have similar programs, Dr. John Marcy, at the University of Arkansas, has developed a very successful "Train the Trainer" program in cooperation with the Arkansas Hotel and Restaurant Association. This program has now been expanded to include child day care centers, another potential for foodborne illness. All involved in food production, both plant and
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regulation is still a compromise! If we are to learn how to compromise we must learn how to assess and manage risk. Risk scientists and risk managers are often coming from a different background. As risk scientists we must learn that "risk trade-offs" can be accepted. A good example of this is the recent negotiation with the Russians on banning American broilers. From the beginning, it was recognized that the ban was based more on internal Russian politics than on unsanitary American broiler plants. Mr. Yeltsin was running for reelection and his rival Communists wanted to stimulate domestic industry and agricultural production and part of their plan was a significant reduction in imports. Dr. Amy Waldroup, of University of Arkansas, has been to Russia several times and visited Russian poultry plants. She reported (Waldroup, personal communication) "I have toured both chicken and turkey processing plants throughout the former Soviet Union. Some of their equipment is very modern; however, sanitation is truly at a minimum. Temperature control does not appear to be very important to Russian processors. In the former Soviet Union, the priority is feeding people—food safety does not appear to be a concern. That is why I was so surprised by the recent problems related to our exports to Russia." When the Russians threatened to ban all exports to U.S. broilers early this year, the risk of an economic disaster was very high, Russia had become the largest market for U.S. poultry exports, with sales of more than $700 million in 1995, almost all of which is the dark meat, usually in surplus in the U.S. An arrangement was made for Russian veterinarians to inspect all the plants shipping broilers to Russia, at a cost to the plant of at least $2,000 per plant. In further negotiations, it was agreed that a Salmonella analysis would be conducted on a 25-g sample of muscle, not skin, per consignment, which could have been a shipload. And furthermore if this sample was positive, a second sample would be taken, and if negative, the consignment cleared. All of us know, based on the USDA baseline data and industry experience, that the chances of rejection were very small. This was certainly not good science but a necessary compromise to lift the poultry ban. In a related event, the International Monetary Fund offered Russia $10.2 billion in new loans, on conditions designed to free international trade, and on the next day the Russians dropped the ban. There is no doubt that politics were an important consideration in Russian poultry import policy.
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a n i m a l , food processors, food distributors, retailers, a n d institution m a n a g e r s , food service o p e r a t o r s , a n d cons u m e r s m u s t p u t e d u c a t i o n at a v e r y h i g h priority. G o o d research only in p r i n t e d journals r e m a i n s just g o o d research. G o o d regulations r e m a i n i n g only in code b o o k s are just g o o d regulations. But, g o o d politics get politicians re-elected. G o o d food safety e d u c a t i o n m e a n s less illness, d e a t h , a n d h u m a n suffering.
REFERENCES
Downloaded from http://ps.oxfordjournals.org/ at Northern Arizona University on June 4, 2015
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